Yitzchok Frankel v. Regents of The University of California
2:24-cv-04702
C.D. Cal.May 21, 2025Background
- Jewish students and a faculty member at UCLA sued the Regents of the University of California and several administrators over their response to a protest encampment on campus that allegedly excluded Jewish individuals.
- Plaintiffs alleged that the protest zone promoted antisemitism and created de facto exclusionary checkpoints, restricting Jewish students’ access unless they made anti-Israel statements.
- Plaintiffs claimed UCLA administrators failed to intervene, enforce university policies, or remove the encampment in a timely way, effectively supporting exclusionary practices.
- Plaintiffs sought damages and injunctive relief under federal (including constitutional and Title VI) and California law, arguing multiple civil rights violations.
- The case came before the court on a motion for judgment on the pleadings filed by individual defendants (university administrators), with further briefings and a hearing.
Issues
| Issue | Plaintiffs' Argument | Defendants' Argument | Held |
|---|---|---|---|
| Qualified immunity for damages (federal claims) | Admins violated clearly established rights | No clearly established law; actions not directly theirs | Qualified immunity applies; damages claims dismissed |
| Individual liability under Title VI | Admins can be sued in official capacities | Only the university (Regents) is liable under Title VI | Title VI claims against admins dismissed |
| Supplemental jurisdiction (state law claims) | (No response/opposition) | Court should decline jurisdiction over state claims | Court declines to exercise jurisdiction over state claims |
| Claims against Defendant Braziel | Maintain official capacity claim against successor | Braziel left before events, claims should be dismissed | All claims against Braziel individually dismissed |
Key Cases Cited
- Harlow v. Fitzgerald, 457 U.S. 800 (1982) (qualified immunity shields government officials unless they violate clearly established rights)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard for pleadings)
- Brown v. Board of Education, 347 U.S. 483 (1954) (state-sponsored racial segregation is unconstitutional)
- Trinity Lutheran Church of Columbia, Inc. v. Comer, 582 U.S. 449 (2017) (states cannot exclude religious entities from public benefits solely due to their religious character)
- Fulton v. City of Philadelphia, 593 U.S. 522 (2021) (government cannot restrict religious conduct while permitting analogous secular conduct)
- National Institute of Family & Life Advocates v. Becerra, 585 U.S. 755 (2018) (state cannot compel speech of a particular message)
- Pearson v. Callahan, 555 U.S. 223 (2009) (order of prongs in qualified immunity analysis is flexible)