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Winfree v. Warren County School District
4:24-cv-00035
E.D. Tenn.
Jul 29, 2024
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Background

  • 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)
Read the full case

Case Details

Case Name: Winfree v. Warren County School District
Court Name: District Court, E.D. Tennessee
Date Published: Jul 29, 2024
Docket Number: 4:24-cv-00035
Court Abbreviation: E.D. Tenn.