879 F. Supp. 2d 438
D. Del.2012Background
- Elliott, a DSU student-athlete, sues for Title VI discrimination, hostile environment, and retaliation.
- Housing dispute: Elliott’s nonwhite suitemate Kristen Williams subjected her to racial abuse and disruption.
- DSU officials (Hall) mediates; Hall minimizes race issues and cautions Elliott against further complaints.
- Elliott later alleges harsh treatment by Coach Arnold, including non-play time, travel restrictions, and scholarship non-renewal.
- DSU eventually removes Williams from the suite; Elliott’s scholarship is not renewed (later disputed as budget-cut related).
- Elliott leaves DSU in 2011 after ongoing disputes, drug testing, and injuries; DSU moves for summary judgment on some claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prima facie Title VI discrimination established? | Elliott claims Hall and Arnold treated her differently than nonwhite peers. | No evidence of race-based differential treatment by DSU officials. | No prima facie discrimination shown; DSU entitled to summary judgment on discrimination. |
| Racially hostile environment exists? | Williams’ conduct created a severe, pervasive hostile environment. | Harassment was not severe or pervasive enough; DSU response was not clearly indifferent. | No hostile environment; DSU entitled to summary judgment on hostile environment claim. |
| Retaliation proven? | Arnold’s harsher treatment followed Elliott’s complaints, with a causal link to protected activity. | Hall’s threats lacking adverse action; Arnold’s conduct generally retaliatory in part. | Trial-worthy issues exist; summary judgment denied on retaliation claim. |
Key Cases Cited
- Davis v. Monroe County Bd. of Educ., 526 U.S. 629 (U.S. 1999) (clear standards for hostile environment under Title VI)
- Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53 (U.S. 2006) (distinguishing significant vs. trivial harms in adverse actions)
- Hendricksen v. Ball State Univ., 107 F. App’x 680 (7th Cir. 2004) (totality-of-circumstances approach for hostile environment)
- Whitfield v. Notre Dame Middle Sch., 412 F. App’x 517 (3d Cir. 2011) (Title IX precedent used in Title VI context)
- Azur v. Chase Bank, USA Nat’l Ass’n, 601 F.3d 212 (3d Cir. 2010) (summary judgment standard in Title VI cases)