Williams v. Penn. State Univ.

697 F.Supp.3d 297

Kayla WILLIAMS, Plaintiff, v. The PENNSYLVANIA STATE UNIVERSITY; Lauren Langford; Karen Feldbaum; and Yvonne Gaudelius, Defendants.

No. 4:20-CV-00298

United States District Court, M.D. Pennsylvania

Signed October 11, 2023

Martell Harris, Nelson D. Berardinelli, The Trial Law Firm LLC, Pittsburgh, PA, for Plaintiff. James A. Keller, Matthew Smith, Saul Ewing Arnstein & Lehr LLP, Philadelphia, PA, for Defendants.

James A. Keller, Matthew Smith, Saul Ewing Arnstein & Lehr LLP, Philadelphia, PA, for Defendants.

MEMORANDUM OPINION

Matthew W. Brann, Chief United States District Judge.

Modern universities are behemoths; educational department stores spread across multiple campuses, combining undergraduate colleges, graduate schools, professional schools, online courses, and research institutions. These institutions have largely displaced—or acquired—smaller colleges guided by more narrow missions. Defendant The Pennsylvania State University epitomizes this evolution. A far cry from its humble beginnings as an agricultural college, Penn State counts nearly 90,000 students on its rolls, with over half of those at its University Park campus.¹ As schools have grown to the size of small cities, so have the administrative institutions within them. American universities maintain police forces, formalized codes of conduct akin to criminal codes, and pseudo judicial institutions which hear and rule on disputes between those on campus and conduct code violations.

Few individuals are more familiar with these features of the modern university and how they interact with their municipal counterparts than Plaintiff Kayla Williams. As a freshman, Williams accused another Penn State student of rape, and alleges that Penn State declined to sanction the accused because she criticized the University's handling of the case. Later, Williams accused a professor of racial bias and alleges he subsequently retaliated against her for levying those accusations. Finally, a few credits short of graduation, Williams herself was accused of harassment and assault, leading to her suspension from Penn State. Williams alleges that, in those proceedings, she was deprived of due process.

There is much less to Williams' claims than meets the eye. Dissatisfaction with adverse academic or disciplinary decisions does not give rise to a legally cognizable harm. Therefore, the Court will grant Defendants' Motion for Summary Judgment.

I. PROCEDURAL HISTORY

Williams filed her eight-count First Amended Complaint on April 27, 2020, against Defendants The Pennsylvania State University, Brandon Prawdzik, Lauren Langford, Karen Feldbaum, and Yvonne Gaudelius.² On September 4, 2020, the Court granted Defendants' Motion to Dismiss³ with regard to Counts V and VI.⁴ Remaining for disposition are Williams' Title VI retaliation (Count I) and discrimination (Count IV) claims, Due Process claims (Counts II and III), and First Amendment Claims (Counts VII and VIII).⁵ Defendants have filed a Motion for Summary Judgment as to each remaining claim,⁶ which is fully briefed by the parties and now ripe for disposition.⁷

II. LEGAL STANDARDS

A. Summary Judgment

Under Rule 56(a) of the Federal Rules of Civil Procedure, summary judgment is appropriate where "the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to a judgment as a matter of law." As expressed by the Supreme Court of the United States in Celotex Corp. v. Catrett, summary judgment is required where a party "fails to make a showing sufficient to establish the existence of an element essential to that party's case" on an issue that the "party will bear the burden of proof at trial."⁸ Material facts are those "that could alter the outcome" of the litigation, "and disputes are 'genuine' if evidence exists from which a rational person could conclude that the position of the person with the burden of proof on the disputed issue is correct."⁹

The party requesting summary judgment bears the initial burden of supporting its motion with evidence from the record.¹⁰ When the movant properly supports its motion, the nonmoving party must then show the need for a trial by setting forth "genuine factual issues that properly can be resolved by only a finder of fact because they may reasonably be resolved in favor of either party."¹¹ The United States Court of Appeals for the Third Circuit explains that the nonmoving party will not withstand summary judgment if all it has are "assertions, conclusory allegations, or mere suspicions."¹² Instead, it must "identify those facts of record which would contradict the facts identified by the movant."¹³

In assessing "whether there is evidence upon which a jury can properly proceed to find a verdict for the [nonmoving] party,"¹⁴ the Court "must view the facts and evidence presented on the motion in the light most favorable to the nonmoving party."¹⁵ Moreover, "[i]f a party fails to properly support an assertion of fact or fails to properly address another party's assertion of fact as required by Rule 56(c)," the Court may "consider the fact undisputed for purposes of the motion."¹⁶ Finally, although "the court need consider only the cited materials, ... it may consider other materials in the record."¹⁷

B. Local Rule 56.1

Local Rule 56.1 requires all motions for summary judgment to be "accompanied by a separate, short, and concise statement of the material facts, in numbered paragraphs, as to which the moving party contends there is no genuine issue to be tried." The party opposing summary judgment must then include with its papers an answer to the movant's statement of facts in which it identifies, in corresponding numbered paragraphs, those material facts which the nonmovant contends there is a genuine issue to be tried.¹⁸ "Statements of material facts in support of, or in opposition to, a motion shall include references to the parts of the record that support the statements."¹⁹ Material facts in the movant's statement "will be deemed to be admitted unless controverted by the statement required to be served by the opposing party."²⁰

1. Statement of Additional Material Facts

In support of their motion for summary judgment, Defendants submitted a 327 paragraph Statement of Undisputed Material Facts.²¹ Williams' answer to Defendant's Statement of Facts responded to each paragraph and included 107 paragraphs of "Additional Material Facts."²² Defendants subsequently filed a motion asking the Court to either strike or allow Defendants to respond to Williams' Statement of Additional Material Facts.²³

Defendants argue that the Court should not exercise its discretion to depart from the requirements of Rule 56.1 because (1) Williams' AMF asserts facts without record support, and (2) Defendants would be prejudiced because they will not have the opportunity to address these inaccuracies.²⁴ These concerns are somewhat undermined by Defendants having taken the initiative to preemptively submit the response—in which they address Williams' purportedly unsupported assertions—that they ask permission to file.²⁵ Williams submitted a single paragraph response, arguing that Defendants' position would preclude her from "point[ing] to sufficient facts on which a jury could find" in her favor, instead forcing her to rely on Defendant's "false narrative."²⁶ In reply, Defendants reiterate their argument that Rule 56.1 does not permit Williams to file her own Additional Material Facts, and assert that it is Williams who is presenting the false narrative.²⁷

As an initial matter, the Court assures the parties that it is not persuaded by the rhetorical flourish of their counterpart. Though counsel may think of themselves as modern day Daniel Websters, no amount of yarn spinning in a Statement of Material Facts will move the Court beyond the bounds of "ordinary range of thought and feeling."²⁸ If the parties agree on a fact, the Court will accept the fact as stated. If they do not, the Court will look to the parts of the record cited by each party and make its own determination. No more, no less. Williams could have denied each of the SMF's paragraphs with citations to the record, and that would have been sufficient to obviate any concerns of a false narrative.

Courts in this District have repeatedly held that "Local Rule 56.1 does not permit a non-moving party to file an additional statement of material facts that does not respond to the moving party's statement."²⁹ Instead, Rule 56.1 "requires the nonmoving party's statement of facts to respond to the numbered paragraphs set forth in the moving party's statement, and to 'include references to the parts of the record that support the statements.'"³⁰ Where the non-movant fails to abide by these requirements of Rule 56.1, the movant's uncontroverted statements of fact may be deemed admitted.³¹ Ultimately, "the proper sanction for violating Rule 56.1 is within the district court's discretion."³²

In determining the proper sanction, the Court is mindful of Rule 56.1's purpose: to "structure a party's summary judgment legal and factual theory into a format that permits and facilitates the court's direct and accurate consideration to the motion."³³ The movant's statement and the non-movant's response should enable "the court to identify contested facts expeditiously."³⁴ Given that Defendants' "short and concise statement of the material facts"³⁵ consists of 327 paragraphs over nearly 100 pages, the Court is skeptical that even strict adherence to the requirements of Rule 56.1 by Williams would make a material difference in the expedience with which the Court is able to identify the contested facts.³⁶

Practically, disregarding Williams' AMF would make it impossible for the Court to evaluate her arguments opposing summary judgment. Williams' opposition brief contains dozens of citations to the AMF.³⁷ Excising those citations and references would render much of Williams' opposition unintelligible, likely resulting...