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 claimed that Professor Paul Belk refused to answer his questions in class, assigned him a zero, 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 gave him information about filing a Title IX complaint and a 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.
The Court’s Holding
The Fifth Circuit affirmed the district court’s judgment for substantially the reasons that court gave. After reviewing the briefs and pertinent parts of the record, the panel found no error affecting the judgment.
The district court had concluded that Taylor lacked standing on his Title IX claim because he did not substantiate a factual dispute concerning a redressable injury. Alternatively, it held that his claim failed because he did not identify an official discriminatory policy or custom, establish deliberate indifference, or identify similarly situated students who received different treatment. It also determined that his due process claims failed as a matter of law.
Key Takeaways
- The Fifth Circuit upheld summary judgment for the College on Taylor’s Title IX and Fourteenth Amendment claims.
- Taylor did not create a genuine factual dispute concerning a redressable injury or essential elements of his Title IX theory.
- The College supplied complaint and appeal options, but Taylor did not pursue them or exhaust administrative remedies.
Why It Matters
The decision illustrates the evidentiary burdens facing a student who seeks to hold a college liable for discrimination under Title IX. Allegations of unfavorable treatment are insufficient at summary judgment without evidence supporting standing and the required elements of the asserted liability theory.
It also shows the significance of an institution’s response to a discrimination complaint: offering complaint procedures, requesting supporting communications, and arranging access to Title IX personnel weighed against Taylor’s deliberate-indifference allegation.