Angela K. Sheets v. Greenville University

Summary

The United States District Court for the Southern District of Illinois addresses Greenville University’s Rule 12(b)(6) motion to dismiss Angela K. Sheets’s claims under Title VII and Title IX. The court dismisses the Title IX retaliation claim concerning assistant-coach assignments as preempted by Title VII, while permitting the Title IX retaliation claim concerning the university’s athletic-complex plan to proceed; the excerpt does not include the complete disposition of all claims.

Holdings

1. Count I was preempted by Title VII because the alleged protected activity concerned discrimination in Sheets's own employment, specifically the allocation of assistant coaches to head coaches, and did not allege opposition to discrimination against female student athletes.
2. Count III adequately pleaded Title IX retaliation and was not preempted by Title VII. Sheets plausibly alleged protected activity, a materially adverse action, and a but-for causal connection between her opposition to sex-based discrimination against female student athletes and her termination.
3. Count II adequately pleaded a Title VII sex-discrimination claim. At the motion-to-dismiss stage, Sheets was required to provide fair notice and plausibly allege that Greenville took a specific adverse employment action against her because of her sex; she was not required to plead a full similarly situated comparator showing or rebut potential nondiscriminatory reasons.

Questions Presented

1. Whether Sheets's Title IX retaliation claim based on her opposition to Greenville's assistant-coach allocation policy was preempted by Title VII because it concerned alleged employment discrimination against Sheets rather than discrimination against student athletes.
2. Whether Sheets adequately pleaded a Title IX retaliation claim based on her opposition to an athletic-complex plan allegedly discriminating against female student athletes.
3. Whether Sheets adequately pleaded a Title VII sex-discrimination claim based on her termination.

Disposition

other