Heineke v. Santa Clara University, No. 18-16348 (9th Cir. 2020)
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The Ninth Circuit affirmed the district court's dismissal of plaintiff's 42 U.S.C. 1983 action alleging violations of the Fourteenth Amendment and of state law arising from the suspension and termination of his employment. In this case, plaintiff was terminated from his position as an economics professor after the university concluded that plaintiff had sexually harassed his former student.
The panel held that SCU, as a private university, does not become a state actor merely by virtue of being required by generally applicable civil rights laws to ameliorate sex (or any other form of) discrimination in educational activities as a condition of receiving state funding. Furthermore, the receipt of federal and state funds conditioned on compliance with anti-discrimination laws is insufficient to convert private conduct into state action.
Court Description: Civil Rights. The panel affirmed the district court’s dismissal of an action brought pursuant to 42 U.S.C. § 1983 alleging violations of the Fourteenth Amendment and of state law arising from the suspension and termination of plaintiff’s employment. Santa Clara University terminated plaintiff’s employment as an economics professor after concluding that plaintiff had sexually harassed his former student. The panel stated that it could not conclude, on the basis of plaintiff’s allegations, that Santa Clara University was a state actor. The panel held that the University, as a private university, does not become a state actor merely by virtue of being required by generally applicable civil rights laws to ameliorate sex (or any other form of) discrimination. The panel further held that receipt of federal and state funds conditioned on compliance with anti-discrimination laws is insufficient to convert private conduct into state action. The panel addressed plaintiff’s other claims in a concurrently filed memorandum disposition. HEINEKE V. SANTA CLARA UNIVERSITY 3
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