Winfree v. Warren County School District
4:24-cv-00035
E.D. Tenn.Jul 29, 2024Background
- Plaintiff Sable Winfree, a high school student, was removed from her basketball team after her coach alleged she used inappropriate language during practice.
- At the time, Winfree had a full scholarship offer from Trevecca Nazarene University and anticipated offers from two other universities, which she alleges were lost as a result of her dismissal from the team.
- Plaintiff was not provided a hearing to challenge her removal nor allowed to present witnesses in her defense.
- Plaintiff filed suit alleging violations of her due process rights and defamation under state law.
- Defendants moved for judgment on the pleadings, challenging the legal sufficiency of Winfree's claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Due process in school athletics removal | Removal from team and loss of scholarship/expected offers created a property interest protectable by due process | No constitutionally protected liberty or property interest in participating in interscholastic athletics | No due process protection for school sports; claim dismissed with prejudice |
| Federal court jurisdiction over state claim | Defamation claim should be heard by the court | If federal claims dismissed, court should not decide state law claims | Declined supplemental jurisdiction; state claim dismissed without prejudice |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (established plausibility standard for pleading)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (set the pleadings standard to "plausible on its face")
- Brindisi v. Regano, 20 F. App’x 508 (6th Cir. 2001) (no protected constitutional interest in interscholastic athletics for students)
- Poling v. Murphy, 872 F.2d 757 (6th Cir. 1989) (school sports participation is a privilege, not a right, under due process)
- Papasan v. Allain, 478 U.S. 265 (1986) (legal conclusions in complaints need not be accepted as true)
