743 F.Supp.3d 824
N.D. Tex.2024Background
- The State of Texas challenged federal agency guidance interpreting Title IX's anti-discrimination provisions to include sexual orientation and gender identity.
- The district court previously issued a Memorandum Opinion, Final Judgment, and granted declaratory and injunctive relief restricting the federal government's Title IX interpretation.
- Texas moved for correction and amendment of the judgment to prevent ambiguity about the scope of relief and its application to future agency actions.
- Defendants did not oppose the clarification but did oppose the expansion of relief to cover more than specific agency guidance documents.
- The Court considered the procedural posture as multiple courts nationwide are addressing challenges to recent Title IX regulations.
- The decision emphasizes both adherence to Fifth Circuit authority and respect for coordination with other district courts handling similar issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Remove ambiguous language from relief | Language could suggest Title IX requires, not prohibits, inclusion of sexual orientation/gender identity | No opposition | Correction granted to clarify relief |
| Scope of injunctive relief (target only certain agency actions or all future actions) | Relief should broadly prohibit all agency actions based on the challenged Title IX interpretation, not just limited documents | Argue relief should be limited to named agency documents/guidance | Expanded, but with the limitation it won't affect pending Final Rule cases elsewhere |
| Consistency with Fifth Circuit precedent | Cites circuit precedent permitting broad injunctive relief against unlawful interpretations | N/A | Court agrees broad relief is permitted under circuit law |
| Impact on parallel litigation over Title IX Final Rule | Relief should not interfere with other ongoing district court cases | N/A | Limited expanded relief so as not to interfere with pending Final Rule challenges in other courts |
Key Cases Cited
- Templet v. HydroChem Inc., 367 F.3d 473 (5th Cir. 2004) (provides standard for amending judgments post-finality)
- Guy v. Crown Equip. Corp., 394 F.3d 320 (5th Cir. 2004) (addresses reconsideration under Rule 59)
- In re Life Partners Holdings, Inc., 926 F.3d 103 (5th Cir. 2019) (motions for reconsideration treated as under Rule 59(e))
- Franciscan All., Inc. v. Becerra, 47 F.4th 368 (5th Cir. 2022) (challenge to agency action is necessarily a challenge to statute enforcement)
- Bostock v. Clayton County, 140 S. Ct. 1731 (2020) (Supreme Court precedent on sexual orientation/gender identity under Title VII)