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Keywords

plaintiffmotiondiscriminationmotion to dismiss

plaintiffdefendantstatutediscrimination

Related Cases

Johnston v. University of Pittsburgh of Com. System of Higher Educ., 97 F.Supp.3d 657, 323 Ed. Law Rep. 152

Facts

Seamus Johnston, a transgender male student, was expelled from the University of Pittsburgh at Johnstown after he refused to stop using male-designated locker rooms and restrooms. Despite identifying as male and having undergone some legal and medical transitions, the university maintained that he could not use these facilities without official documentation reflecting a change in his gender. Following a series of disciplinary actions, including citations for disorderly conduct, Johnston was ultimately expelled, leading him to allege discrimination based on his sex and transgender status under Title IX and the Equal Protection Clause.

Issue

Did the university's actions in prohibiting Johnston from using male-designated facilities constitute discrimination based on sex and transgender status in violation of Title IX and the Equal Protection Clause?

Whether a university, receiving federal funds, engages in unlawful discrimination, in violation of the United States Constitution and federal and state statutes, when it prohibits a transgender male student from using sex-segregated restrooms and locker rooms designated for men on a university campus.

Rule

To establish a claim under the Equal Protection Clause, a plaintiff must show purposeful discrimination based on sex. Under Title IX, discrimination based on sex includes retaliation against individuals who complain about such discrimination. The court applies a rational basis standard for classifications that do not target a suspect class or burden a fundamental right.

Analysis

The court found that Johnston failed to demonstrate that he was treated differently from similarly situated individuals, as he did not provide sufficient evidence of purposeful discrimination. The university's policy of segregating facilities based on biological sex was deemed to serve a legitimate governmental interest in privacy. Furthermore, Johnston's claims under Title IX were dismissed as the court interpreted 'sex' in a traditional binary sense, consistent with birth sex.

Even if intermediate scrutiny, rather than rational basis review, applied to student's equal protection claims against university and its employees based on his transgender status, university's policy of segregating its bathroom and locker room facilities on the basis of birth sex was substantially related to a sufficiently important government interest and therefore did not violate the Equal Protection Clause; policy was based on university's need to ensure the privacy of its students to disrobe and shower outside of the presence of members of the opposite sex. U.S.C.A. Const.Amend. 14.

Conclusion

The court granted the university's motion to dismiss, concluding that Johnston did not state a plausible claim for discrimination or retaliation under Title IX or the Equal Protection Clause.

The simple answer is no.

Who won?

The University of Pittsburgh at Johnstown prevailed in this case as the court found that Johnston's claims did not meet the legal standards required to establish discrimination or retaliation. The court emphasized that the university's policies were based on legitimate privacy concerns and that Johnston's failure to provide necessary documentation to change his gender designation contributed to the dismissal of his claims.

Defendants argue that Plaintiff's complaint fails to state a cognizable Equal Protection Claim as a matter of law.

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