S.N., a minor child, by and through her parents, A.N. and C.N., and on their own behalf v. Independent School District No. 630

Summary

The United States District Court for the District of Minnesota denied without prejudice a motion for a preliminary injunction seeking to compel a school district to allow a student to play varsity girls’ basketball for a neighboring district through a cooperative sponsorship. Applying the Title IX participation-opportunity framework and the Dataphase factors, the court found a viable athletic opportunity but no sufficient showing that the district acted unreasonably or discriminatorily, and concluded that timing, administrative constraints, and program disruption weighed against interim relief.

Holdings

1. At the preliminary-injunction stage, Plaintiffs did not demonstrate a likelihood of proving that the District violated Title IX by failing to reasonably accommodate girls' varsity basketball.
2. The Dataphase factors did not support preliminary injunctive relief.
3. The Title IX athletics three-part framework remained applicable because it interprets the Department of Education's regulation, and its continued use was not displaced by Loper Bright Enterprises v. Raimondo.

Questions Presented

1. Whether Plaintiffs were likely to succeed on their Title IX claim that Red Lake Falls failed to reasonably accommodate a viable opportunity for girls' varsity basketball under the third prong of the Title IX athletics framework.
2. Whether the Dataphase factors supported a preliminary injunction requiring Red Lake Falls to facilitate S.N.'s participation on Red Lake County Central's varsity girls' basketball team after the season had begun.
3. Whether the requested midseason cooperative sponsorship was feasible and consistent with the public interest in orderly administration of interscholastic athletics.

Disposition

denied