The Women's Student Union v. U.S. Department of Education

CourtDistrict Court, N.D. California
DecidedFebruary 16, 2022
Docket3:21-cv-01626
StatusUnknown

This text of The Women's Student Union v. U.S. Department of Education (The Women's Student Union v. U.S. Department of Education) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The Women's Student Union v. U.S. Department of Education, (N.D. Cal. 2022).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 THE WOMEN’S STUDENT UNION, Case No. 21-cv-01626-EMC

8 Plaintiff, ORDER GRANTING DEFENDANT’S MOTION TO DISMISS FOR LACK OF 9 v. SUBJECT MATTER JURISDICTION, AND DENYING AS MOOT MOTIONS 10 U.S. DEPARTMENT OF EDUCATION, TO INTERVENE 11 Defendant. Docket Nos. 82, 88, 89

12 13 14 Plaintiff the Women’s Student Union (“WSU”) sues Defendant the U.S. Department of 15 Education (the “Department”) to set aside regulations enacted in 2020 that reduce federal 16 protections for students enrolled in public schools from sexual harassment and sexual violence 17 under Title IX of the Education Amendments of 1972, 20 U.SC. § 1681(a). See Docket No. 78 18 (“FAC”) ⁋ 8 (citing 85 Fed. Reg. 30,026 (May 19, 2020) (codified at various places in 34 C.F.R. 19 Pt. 106) (the “2020 Regulations”)). Plaintiff alleges that the 2020 Regulations violate the 20 Administrative Procedure Act (APA), 5 U.S.C. §§ 706(2)(A), (C), because they are contrary to the 21 text and purpose of Title IX. FAC § Claim ¶¶ 1-7. The Court previously dismissed Plaintiff’s 22 complaint because, as alleged, the complaint did not demonstrate that Plaintiff had standing under 23 Article III to pursue its claims. Docket No. 75 (“Dismissal Order”). The Court granted Plaintiff 24 leave to amend its complaint, which Plaintiff did. 25 Now pending before the Court is the Department’s motion to dismiss Plaintiff’s First 26 Amended Complaint for lack of subject matter jurisdiction pursuant to Federal Rule of Civil 27 Procedure 12(b)(1). See Docket No. 89 (“MTD”). Also pending before the Court are motions to 1 Rights in Education, Independent Women’s Law Center, and Speech First, Inc. Docket Nos. 82, 2 88. 3 For the following reasons, the Court GRANTS the Department’s motion because Plaintiff 4 lacks standing. Accordingly, the Court DENIES as moot the motions to intervene. 5 I. BACKGROUND 6 A. Title IX Enforcement Before the 2020 Regulations 7 Title IX of the Education Amendments states that “[n]o person in the United States shall, 8 on the basis of sex, be excluded from participation in, be denied the benefits of, or be subjected to 9 discrimination under any education program or activity receiving Federal financial assistance.” 20 10 U.S.C § 1681(a). The statute defines “program or activity” as “all of the operations” of a school, 11 “any part of which is extended Federal financial assistance.” Id. § 1687. Federal agencies that 12 disburse funds to educational institutions—including the Department of Education—are 13 “authorized and directed” by Congress to “effectuate the provisions of” Title IX “by issuing rules, 14 regulations, or orders of general applicability.” Id. § 1682. These agencies can compel school 15 districts to comply with the provisions of Title IX—and its implementing regulations—by 16 threatening to withhold federal education funds from noncompliant school districts. Id. 17 There are two ways to enforce Title IX. First, a plaintiff (usually a student) can sue a 18 school for damages in federal court as Title IX provides a private right of action. See Franklin v. 19 Gwinnett Cnty. Pub. Sch., 503 U.S. 60, 76 (1992). In such cases, however, students can recover 20 “only for harassment that is so severe, pervasive, and objectively offensive that it effectively bars 21 the victim’s access to an educational opportunity or benefit,” and they must prove the school’s 22 “deliberate indifference to known acts of harassment in its programs or activities.” Davis v. 23 Monroe Cnty. Bd. of Educ., 526 U.S. 629, 633 (1999). This standard is met only if “an official 24 who at a minimum has authority to address the alleged discrimination and to institute corrective 25 measures on the recipient’s behalf has actual knowledge of discrimination in the recipient’s 26 programs and fails adequately to respond.” Gebser v. Lago Vista Indep. Sch. Dist., 524 U.S. 274, 27 290 (1998). This strict definition of sexual harassment and the requirements of actual knowledge 1 Second, Title IX may be enforced administratively by the Department through the issuance 2 of rules, regulations, and guidance documents. See Gebser, 524 U.S. at 292 (“Agencies generally 3 have authority to promulgate and enforce requirements that effectuate the statute’s 4 nondiscrimination mandate, 20 U.S.C. § 1682, even if those requirements do not purport to 5 represent a definition of discrimination under the statute.”). The Department’s own regulations 6 require its Office for Civil Rights (OCR) to investigate any administrative complaint it receives 7 from a member of the public that indicates gender-based discrimination or sexual harassment. See 8 34 C.F.R. § 100.7(c) (“[R]esponsible Department official or his designee will make a prompt 9 investigation whenever a . . . complaint . . . indicates a possible failure to comply.” (emphasis 10 added)); id. § 106.71 (Title IX regulation incorporating the procedural provisions of the 11 Department’s Title VI regulations). If the investigation “indicates a failure to comply” with the 12 regulations, the OCR “will so inform the recipient and the matter will be resolved by informal 13 means whenever possible.” Id. § 106.7(c). Because investigations are required, Plaintiff alleges 14 school districts are almost always willing to settle to avoid the termination of their federal funding. 15 See FAC ⁋ 75. 16 Plaintiff alleges that prior to the 2020 Regulations, the Department’s guidance 17 “consistently rejected the view that the courts’ standards for determining whether a private 18 damages action could be brought against a school should be incorporated into its administrative 19 enforcement process.” FAC ⁋⁋ 27–28 (citing Sexual Harassment Guidance, 62 Fed. Reg. 12,034 20 (Mar. 13, 1997) (the “1997 Guidance”); Revised Sexual Harassment Guidance, 66 Fed. Reg. 21 5,512-01 (Jan. 19, 2001) (the “2001 Guidance”)). Instead, the 2001 Guidance adopted a scope of 22 liability for administrative enforcement of Title IX broader than the Gebser/Davis framework. It: 23 (1) defined sexual harassment as “unwelcome conduct of a sexual nature” that is “severe, 24 persistent, or pervasive;” and (2) stated that a school may be liable “whether or not it has ‘notice’ 25 of the harassment.” U.S. Dep’t of Educ., Off. for Civil Rights, Revised Sexual Harassment 26 Guidance: Harassment of Students by School Employees, Other Students, or Third Parties (Jan. 27 19, 2001), https://www2.ed.gov/about/offices/list/ocr/docs/shguide.pdf (emphasis added). 1 B. The 2020 Regulations Incorporated the Gebser/Davis Framework 2 On May 19, 2020, under the leadership of then-Secretary of Education Elisabeth DeVos, 3 the Department issued the 2020 Regulations, which repudiated the Department’s prior guidance, 4 and largely aligned the standards for the OCR’s adjudication of Title IX administrative complaints 5 with the Gebser/Davis framework. See 85 Fed. Reg.

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