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Keywords

lawsuitplaintiffappealcomplianceclass actionequitable relief
trialdiscriminationappellee

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Pederson v. Louisiana State University, 213 F.3d 858, 46 Fed.R.Serv.3d 243, 46 Fed.R.Serv.3d 1254, 145 Ed. Law Rep. 113

Facts

Three female undergraduate students at Louisiana State University (LSU) filed a lawsuit against the university and its officials, alleging violations of Title IX by denying them equal opportunities to participate in intercollegiate athletics. The plaintiffs sought to represent a class of female students who were similarly affected by the university's failure to field women's varsity teams in sports like soccer and fast-pitch softball. The district court initially provisionally certified the class but later decertified it, leading to appeals regarding the university's compliance with Title IX and the standing of the plaintiffs.

Issue

Did the district court err in decertifying the class based on lack of numerosity and in its findings regarding the university's violation of Title IX?

Did the district court err in decertifying the class based on lack of numerosity and in its findings regarding the university's violation of Title IX?

Rule

Under Title IX, educational institutions receiving federal funds must provide equal athletic opportunities for both sexes. The court reviews class certification decisions for abuse of discretion, and the numerosity requirement must be satisfied to maintain a class action. A plaintiff must demonstrate a concrete injury, causation, and redressability to establish standing.

Analysis

The appellate court found that the district court abused its discretion by decertifying the class due to a lack of numerosity, as there was sufficient evidence of interest among female students in participating in the sports in question. The court also determined that the university's failure to provide equal athletic opportunities constituted an intentional violation of Title IX, as it was based on outdated assumptions about female athletes.

The district court abused its discretion when it decertified, for lack of numerosity, class of female university students who were not allowed to participate in varsity intercollegiate athletics due to university's failure to field teams, where district court failed to identify specific findings that led it to this conclusion, in light of evidence that a number of current university female students had desire to try out for varsity soccer or fast-pitch softball and that, near time of trial, over 5,000 young women were playing those sports at high school level in the state.

Conclusion

The appellate court affirmed in part, reversed in part, vacated in part, and remanded the case for further proceedings, concluding that the university had violated Title IX and that the class should be reconsidered for certification.

The district court ruled that Appellees were in violation of Title IX.

Who won?

The plaintiffs prevailed in their appeal, as the appellate court found that the district court had erred in its decertification of the class and in its conclusions regarding the university's compliance with Title IX. The court emphasized that the university's failure to accommodate female athletes was intentional, which supported the plaintiffs' claims for equitable relief.

The appellate court found that LSU violated Title IX by failing to accommodate effectively the interests and abilities of certain female students and that its discrimination against these students was intentional.

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