Bennett Vs Texas Wrestling Association Case Study

I. Citation
Barnett v. Texas Wrestling Association (1998): online http://www.leagle.com/decision/199870616FSupp2d690_1635/BARNETT%20v.%20TEXAS%20WRESTLING%20ASS'N

II. Key Facts
1. During the 1996-1997 school year, the plaintiffs were juniors in the Arlington Independent School District and were members of their schools varsity wrestling team. In November of 1996, plaintiffs attended the North Texas Open wrestling tournament. When requesting to compete in mixed gender matches at the tournament, official members of TIWA and TWOA who were sanctioning the event denied them pursuant to a rule established by TIWA. In December of 1996, the plaintiffs brought this issue to the courts claiming that the associations sanctioning the tournament

had violated their rights and asked for injunctive relief as well as compensatory and punitive damages.. The court denied the request for a TRO and ordered the parties to submit affidavits addressing the plaintiff’s request. The court denied the plaintiff’s request for a preliminary injunction. The court also denied the defendants’ motions to dismiss the case. Primary opinion for this was the lack of ability to provide relief asked for; from an entity that had no liability to provide this relief. Additional briefs were requested by the court to determine resolution.

III. Issues Presented to the Court
1.

Title IX of the Education Amendments of 1972, which generally prohibits the discrimination of an athlete based on the gender of that particular athlete in athletic events. The court concluded that the plaintiffs may not claim discrimination under Title IX. Even though there is a lack of a Title IX violation, the actions of the defendants were still potentially unlawful. According to the Fourteenth Amendment, “No State shall…deny to any person within its jurisdiction the equal protection of the laws.” As alleged here, those who were in charge of the sanctioned event, discriminated against the plaintiffs based on their gender. For those who are seeking to defend their reasoning for denying the plaintiffs permission to participate in the mixed gender matches, must demonstrate a persuasive justification for their action of denying the participation. The IISD and schools did not have a discriminatory policy in place. Due to the absence of the plaintiff’s constitutional claims, the courts say that it isn’t clear that the Fourteenth Amendment was violated when the plaintiffs were denied permission in the mixed gender competition. These associations did not offer a mixed gender competition it was argued. No anti-discriminatory policies are written and in

effect.
Schools that are part of IISD have voluntarily joined TIWA and employed TWOA officials and those who were employed had agreed to the rules that were put in place by the association and had agreed to follow them.

Upon agreeing to these rules put in place, they enforced them during any type of school-sponsored event. The defendants say that the IISD board was unaware of any type of anti-discrimination policy that was put in place; there was concern that the IISD did not formally put into place the associations’ formal policy of discrimination, because of the close relationship of the TIWA, TWOA, and IISD schools. These policies put into place by TIWA and TWOA are “state action.” The plaintiffs’ claims for compensatory damages are allowed to proceed to trial because they have presented the substantial evidence where it could be found in their favor if presented to a rational

jury.
The punitive damages that the plaintiffs claim to have, failed as a matter of law and the courts will order a summary judgment based on these claims. IISD’s position is to determine that these claims were not in accordance with the law and the plaintiffs have not contested this.

IV. Decision of the Court
The court had determined based on previous case law that just because Title IX exclusions did not apply since these associations of the TIWA and TWOA are not direct receivers of Title IX funds disbursed by congress they are free to offer these single gendered events without fear of violation of the Title IX regulations.

V. Reasoning of the Court
Possible actions to exclude from the benefit of the 14th amendment under state law are recognized, but these actions to exclude need to be based on a legislative proceeding enacting said regulation. These associations did not act in such a capacity.
Communication was provided to both parties that judgement was being summarily entered, and each party had opportunity to provide additional evidence supporting either the defendant or plaintiff’s interpretation of the facts and the applicable law.
Based on the facts presented the court summarily decided that Title IX provisions did not apply to the plaintiff’s requested remedies in this case.
There are established precedents that with title IX that allows for establishment of gender segregated activities based on competitive skills or if the activity is quintessentially a contact sport. Wrestling is definitely a contact sport. The Fifth circuit and lower courts have granted that regulations promulgated by both the US Department of Education and the Department of Health and Human Services are allowable. Based on these, the defendants were free to exclude the plaintiffs.
For lawful exclusion of participants based on the Fourteenth amendment, there must be some governmental objective and the exercise of that action is related to that objective’s achievement. No written policy to exclude is required, but the policy must be sufficient indoctrinated into the activity that it functions essentially as a written policy or statute. However, municipal subdivisions of the state cannot be held liable for the wrongdoing of others.
Defendants did not address the plaintiff claims constitutional claims. The IISD claims to not have a discriminatory policy, and the TWOA and the TWIA are not state subdivisions and as such no relief is applicable from them.
However since these are voluntary associations, lack of knowledge of potentially discriminatory policies, and as state actors a jury can reasonably argue and determine based on facts presented a potential remedy.
Punitive damages are not allowed as states by law are excluded from this remedy.
Injunctive relief was basically denied due to the facts presented that the plaintiffs are now out of the varsity career age of participation, and further injury is not likely. Further these associations have dissolved any agreements with the municipal subdivisions and the TWOA and TWIA have disbanded. In addition, the IISD has adopted new anti-discriminatory policies. The UISL is now the agency in charge of these competitive activities.
Summary judgement was provided to the defendants due to the availability of further procedural and administrative paths to address claims with the IISD and TWOA organizations.

In summary the plaintiffs are allowed to continue pursuit of their claim for compensatory damages, while relieving the defendants of responsibility for injunctive and punitive relief.