Lazor v. University of Connecticut, 560 F.Supp.3d 674

Plaintiffs are members of the University of Connecticut (UConn) women’s varsity rowing team; UConn announced on June 24, 2020 it would eliminate the women’s rowing team (and two men’s teams) citing budgetary concerns.
Plaintiffs sued alleging Title IX violation (failure to provide athletic opportunities substantially proportionate to female enrollment) and sought a temporary restraining order (TRO) to preserve the team pending a preliminary injunction hearing.
The court held a hearing on May 20, 2021, treated the requested relief as preserving the pre-cut status quo, but applied the higher mandatory-injunction scrutiny as well.
On the merits the court focused on Title IX prong one (substantial proportionality), finding UConn’s participation gap (20–34 athletes depending on year) large enough to support a viable team and that UConn’s reliance on average team size and a <2% safe-harbor was unpersuasive.
The court found plaintiffs would suffer irreparable harm (loss of opportunity, team continuity, mentorship) and that the delay in filing (~10 months) was justified by pandemic-related and investigatory reasons.
The court balanced the equities and public interest in favor of plaintiffs and granted a TRO enjoining elimination of the team, termination of coaches, reductions in support, and denial of access to facilities or competition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Likelihood of success on Title IX (Prong One: substantial proportionality)	UConn has a persistent participation gap sufficient to field a viable women’s team; historical shortfall shows noncompliance	Gap is small; average women’s team size exceeds gap; participation-gap % (~1.33%) is negligible	Court found a substantial likelihood plaintiffs prevail; rejected dispositive use of average team size and any bright-line % safe harbor
Injunction standard: mandatory vs prohibitory	TRO preserves the last peaceable status quo (team operative) — prohibitory relief	UConn points to post-announcement steps (no recruiting, staffing) and urges mandatory standard	Court characterized relief as preserving status quo (prohibitory) but applied the higher standard anyway and found plaintiffs meet it
Irreparable harm from cutting the team	Loss of irreplaceable athletic opportunities, mentorship, continuity; monetary relief inadequate	Delay in filing (~10 months) and University financial burden	Court found irreparable harm; delay excused by pandemic and investigatory efforts; harms to athletes weigh heavily
Balance of equities & public interest	Athlete harms outweigh financial hardship; public interest favors enforcing Title IX	University cites operational/financial prejudice and timing concerns	Court held equities and public interest favor plaintiffs; TRO issued to maintain team and related support

Glossip v. Gross, 576 U.S. 863 (2015) (articulates the factors for injunctive relief)
Biediger v. Quinnipiac Univ., 691 F.3d 85 (2d Cir. 2012) (interprets Title IX three-part test and rejects a bright-line statistical safe harbor)
Cacchillo v. Insmed, Inc., 638 F.3d 401 (2d Cir. 2011) (distinguishes mandatory from prohibitory injunctions and relates standard of review)
North America Soccer League LLC v. United States Soccer Federation, 883 F.3d 32 (2d Cir. 2018) (defines the relevant status quo for injunction analysis)
Tom Doherty Assocs., Inc. v. Saban Ent., Inc., 60 F.3d 27 (2d Cir. 1995) (delay may undermine a claim of irreparable harm)
Tough Traveler, Ltd. v. Outbound Prod., 60 F.3d 964 (2d Cir. 1995) (delay in seeking relief can undercut urgency for injunctive relief)
Quaratino v. Tiffany & Co., 166 F.3d 422 (2d Cir. 1999) (public interest in enforcing private civil rights supports injunctions)
Warner-Lambert Co. v. Northside Dev. Corp., 86 F.3d 3 (2d Cir. 1996) (monetary hardship to defendant can be compensable; relevant in equity balancing)