Appeals Court Affirms Dismissal of Title IX Suit Based on Coach’s Actions

Plaintiff Chloe Murphy sued Northside Independent School District for sex discrimination under Title IX and for violating her constitutional right to due process. Her lawsuit alleged injuries she allegedly sustained after her cheerleading coach made the team perform 150-200 “frog jumps” as punishment for her tardiness, resulting in rhabdomyolysis, a muscle injury. Murphy claimed her injuries were due to inequitable funding practices and inadequate training at the school. The district court dismissed her suit for failure to state a claim, and the appellate court affirmed this dismissal.

The appellate court reviewed the district court’s decision de novo and applied the standard that a plaintiff must plead enough facts to make a claim plausible. Under Title IX, Murphy needed to demonstrate that the school intended to treat women differently based on sex. However, she did not provide facts suggesting intentional sex-based discrimination. The punishment by the coach violated the school’s express policy against using physical activity as punishment, but there was no evidence linking the alleged inequitable funding to her injury.

Murphy also referenced regulations for college sports under Title IX, but these were not directly applicable to her case. Even if they were, her claim lacked sufficient factual support to be plausible. Regarding her constitutional claim under § 1983, Murphy needed to show that a constitutional violation occurred and was driven by an official policy. She failed at the first step, as the court’s precedent in a similar case determined that using exercise as punishment does not constitute a constitutional violation.

The court reiterated that as long as there is an adequate state remedy, public school students cannot claim denial of substantive due process for excessive corporal punishment. Since Murphy did not plead a valid Title IX claim or a constitutional cause of action, the district court’s judgment was affirmed. Thus, the dismissal of her lawsuit was upheld, emphasizing the need for specific factual allegations to support claims of discrimination and constitutional violations in such cases. The case is Murphy v. Northside Indep. Sch. Dist., No. 23-50369, 2024 WL 1554057 (5th Cir. Apr. 10, 2024).

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