Elizabeth Ondina Wright v. University of Utah, a political subdivision of the State of Utah, and Scott Hitesman, Charles Cavanagh, Sergeant Laramie Lancaster, and Ashley Renzi

Summary

The United States District Court for the District of Utah partially grants and partially denies defendants’ motion to dismiss claims arising from Elizabeth Wright’s ejection from a University of Utah basketball game. The court allows Wright’s Title VI discrimination claim against the University of Utah to proceed, but dismisses without prejudice her Equal Protection claim against Sergeant Laramie Lancaster based on qualified immunity. The court declines to dismiss the breach of contract claim and permits amendment within 30 days.

Holdings

1. On a Rule 12(b)(6) motion, the court will not consider external evidence that was not incorporated into, attached to, or referenced in the complaint and that defendants offered to undermine the complaint’s factual allegations.
2. Wright plausibly alleged a Title VI claim against the University by alleging that she was treated adversely because of race or national origin and was treated less favorably than her similarly situated white husband.
3. Wright did not plead a class-of-one Equal Protection claim; she alleged traditional race-based discrimination.
4. Sergeant Lancaster was entitled to qualified immunity because Wright did not carry her burden to show that Lancaster violated her constitutional rights or that the right was clearly established on the alleged facts.
5. Defendants’ request to delay or limit discovery so Wright and the University could resolve a contractual dispute was not appropriately raised in a motion to dismiss, and the court did not dismiss the breach-of-contract claim.

Questions Presented

1. Whether the court could consider body-camera footage and Stadium Guest Information webpages attached to the motion to dismiss.
2. Whether Wright plausibly alleged an intentional race or national-origin discrimination claim under Title VI against the University.
3. Whether Wright plausibly alleged an adverse action and disparate treatment compared with her similarly situated white husband.
4. Whether Wright’s Fourteenth Amendment Equal Protection claim was a class-of-one claim.
5. Whether Sergeant Lancaster was entitled to qualified immunity on the Equal Protection claim.
6. Whether defendants’ request concerning Wright’s breach-of-contract claim was properly raised on a motion to dismiss and whether supplemental jurisdiction should be declined.

Disposition

other