Unreported / Non-Citable
Background
Joey Taylor, a gay student at Collin County Community College District, alleged that the College violated Title IX and the Fourteenth Amendment by discriminating against him based on his sexual orientation. He asserted that Professor Paul Belk refused to answer his questions during class, gave him a zero on an assignment, and filed a student incident report after an email exchange in which Taylor engaged in threatening behavior.
Taylor also alleged that the College acted with deliberate indifference by failing to investigate his complaint independently. The College informed him how to pursue a Title IX complaint and grade appeal, requested his communications with Belk, and coordinated a meeting with Title IX officers, but Taylor did not pursue those avenues or exhaust administrative remedies.
The district court granted summary judgment to the College. It concluded that Taylor lacked standing because he had not established a factual dispute concerning a redressable injury and, alternatively, that his Title IX and due process claims failed as a matter of law.
The Court’s Holding
The Fifth Circuit affirmed the district court’s judgment. After reviewing the briefs and pertinent portions of the record, the panel found no error that would affect the judgment and adopted substantially the same reasoning as the district court.
The district court’s alternative merits analysis found no factual dispute showing an official policy or custom of discrimination, deliberate indifference by the College, or similarly situated students who received different treatment. It also concluded that Taylor’s due process claims failed as a matter of law.
Key Takeaways
- The Fifth Circuit affirmed summary judgment for Collin College on Taylor’s Title IX and Fourteenth Amendment claims.
- The College provided Taylor with procedures for filing a Title IX complaint and grade appeal, but he did not pursue them or exhaust administrative remedies.
- The appellate court found no reversible error and affirmed substantially for the reasons given by the district court.
Why It Matters
The decision illustrates the evidentiary hurdles facing a student who alleges discrimination by a college. A plaintiff must establish standing and produce evidence supporting the required elements of the claim, including institutional responsibility rather than relying solely on allegations about an individual professor’s conduct.
It also underscores the practical importance of using available complaint and appeal procedures, particularly when the institution offers to review communications and arrange a meeting with Title IX personnel.