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Keywords

plaintiffdefendantdamagesattorneyappealsummary judgmentdiscrimination
attorneystatutediscriminationcivil rights

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Horner v. Kentucky High School Athletic Ass’n, 206 F.3d 685, 142 Ed. Law Rep. 728, 2000 Fed.App. 0096P

Facts

Female high school athletes in Kentucky sued the Kentucky State Board of Education and the Kentucky High School Athletic Association, claiming that the failure to sanction fast-pitch softball for girls violated equal protection, Title IX, and state law. The district court granted summary judgment for the defendants on the equal protection and Title IX claims. The athletes appealed, and the Court of Appeals affirmed the judgment on the equal protection claim but reversed on Title IX. On remand, the district court again granted summary judgment for the defendants on the Title IX claim, leading to another appeal by the athletes.

Issue

Did the Kentucky High School Athletic Association's failure to sanction fast-pitch softball for girls constitute a violation of Title IX and equal protection?

Did the Kentucky High School Athletic Association's failure to sanction fast-pitch softball for girls constitute a violation of Title IX and equal protection?

Rule

Under Title IX, proof of intentional discrimination is required for monetary damages when a facially neutral policy is challenged under a disparate impact theory. The burden of proving statistical disparity and unmet interest lies with the plaintiffs. Title IX does not mandate perfect parity but requires equality of athletic opportunity.

Analysis

The court analyzed whether the athletes could demonstrate intentional discrimination under Title IX. It found that the athletes failed to provide evidence of intentional discrimination, as they only presented proof of statistical disparity without showing that the defendants acted with discriminatory intent. The court emphasized that the mere existence of a boys' fast-pitch softball team did not establish a violation of Title IX, as the defendants had complied with the law by offering equal opportunities based on student interest.

Conclusion

The court affirmed the district court's ruling, concluding that the athletes did not prove a violation of Title IX or intentional discrimination, and thus were not entitled to damages or attorney fees.

Affirmed.

Who won?

The Kentucky High School Athletic Association and the Kentucky State Board of Education prevailed in this case. The court found that the plaintiffs failed to demonstrate intentional discrimination under Title IX, which is a prerequisite for monetary damages. The defendants had complied with Title IX by offering equal opportunities based on the interests of the member schools, and the plaintiffs did not provide sufficient evidence to support their claims.

There was no clear error in finding that female high school athletes who brought Title IX suit challenging failure of athletic association to sanction fast-pitch softball for girls were not prevailing parties for purposes of civil rights attorney fee statute, after no intentional discrimination was shown and claims for injunctive and declaratory relief were found moot when state legislature amended statute.

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