By Michael G. McLendon
Background
The case, Ben-Oni v. Wood, is between Plaintiff Josiah Malchiel Israel Ben-Oni, representing himself against Defendants Jonathan Luke Wood, and the Associated Students Incorporated (“ASI”) of the University of California Sacramento. This case is still ongoing. Plaintiff argues that the ASI is violating students’ constitutional rights through their petition process and raising fees to build a stadium for the school (Ben-Oni v. Wood, n.d., p.2). Plaintiff requests a preliminary injunction to stop the stadium construction and is seeking a temporary restraining order (“TRO”) on the defendant. The primary complaint is that the ASI violates Plaintiff’s First and Fourteenth Amendment rights by not following the correct process to seek approval to increase ASI fees (Ben-Oni v. Wood, n.d., p.1). Most recently, the court decided this request for a TRO and injunction to stop construction is DENIED (Ben-Oni v. Wood, n.d., p.5).
“The legal framework of this case contains federal civil rights statutes 42 U.S.C. § 1983 (case text, 2024, p.1).” This statute allows individuals to sue for constitutional violations committed by people acting under state law. “The plaintiff, Ben-Oni, alleged that the defendant, Wood, acting in an official capacity, violated students’ constitutional rights. The rights in question were freedom of speech in the First Amendment and equal protection in the Fourteenth Amendment.” (Ben-Oni v. Wood, n.d., p.1).
Plaintiff had four separate claims and/or requests to the court, which consisted of the following:
- ASI to not impose increasing fees;
- The fee increase was approved by depriving students of their rights to democratic participation in governance under the First Amendment and Fourteenth Amendment;
- Stop the construction of an athletic stadium at California State University Sacramento; and
- Stop Defendants from enforcing ASI Operating Rule 200.6.
Plaintiff argued the fee increase for the Fall of 2025 ($508 increase) and the current 2023 fee increase ($96) caused a “financial burden” that will “hinder students’ access to educational opportunities, compromise the quality of their academic experience and suppress student engagement” (Ben-Oni v. Wood, n.d., p.5). “The Plaintiff also argue[d] that ASI Operating Rule 200.6 has many stipulations that hinder to participate in petitions (ASCSUS OPERATING RULES Revised, 2024). “The Plaintiff claimed this criterion negatively impacts marginalized groups violating the First Amendment’s free speech protections and the Fourteenth Amendment’s Equal Protection Clause.” (Ben-Oni v. Wood, n.d., P.2):
- This clause violates the First Amendment because it restricts people from the right to petition.
- This clause violates the 14th Amendment because it disproportionately impacts on certain groups violating equal protection (Ben-Oni v. Wood, n.d., P.2).
On October 8, 2024, Plaintiff filed motions for a TRO and a preliminary injunction to halt the fee increases, stadium construction, and enforcement of ASI Operating Rule 200.6. “The court denied these motions on October 11, 2024, citing insufficient evidence to support the claims of constitutional violations.” (Ben-Oni v. Wood, n.d., P.5).
Plaintiff then filed motions for reconsideration and electronic filing privileges. “On November 18, 2024, the court denied these motions but granted the Plaintiff’s request to amend his complaint, allowing him fourteen days to file an amended version.” (casetext.com, 2024, p.1). The court had to determine the constitutionality of fee increases and stadium construction. The court also had to review whether Defendants’ implementation of a $508 fee increase scheduled for Fall 2025, an earlier $96 increase in Fall 2023, and the planned construction of a new athletic stadium violated Plaintiff’s First and Fourteenth Amendment rights by imposing financial burdens that could hinder students’ access to education and suppress student engagement (Ben-Oni v. Wood, n.d., p.2). To succeed on the request for a preliminary injunction, Plaintiff must satisfy the following four conditions:
- “Likelihood of success on the merits
- likelihood of irreparable harm in the absence of preliminary relief
- that the balance of equities tips in his favor
- that an injunction is in the public interest.” (Ben-Oni v. Wood, n.d., p.2)
Ultimately, the court decided as follows:
- The likelihood of success on the merits were not founded.
The court determined that the ASI does not violate the First and Fourteenth Amendments. Plaintiff claims ASI 200.6 disproportionally affects transfer, undocumented, and international students. The court determined that they could not find noteworthy evidence to prove this claim or that eligibility criteria is arbitrary. “They also found that transfer students are not considered in a protected category to leverage the Fourteenth Amendment argument.” (Ben-Oni v. Wood, n.d., p. 3-4)
- Likelihood of Irreparable Harm was not founded.
The court determined that Plaintiff could not show the rise in fees, construction of the stadium, or using ASI 200.6 brought immediate impacts to access of education for students. Specifically, the court ruled, “Plaintiff has not demonstrated how the Fall 2025 fee increase or the construction of the stadium immediately impacts students’ access to education beyond a potential future economic harm.” (Ben-Oni v. Wood, n.d., P.4)
- Balance of Hardships and Public Interest were also not founded.
The court found that the balance of hardships, if they supported an injunction to stop fees and construction of the stadium, would not favor Plaintiff, and stopping both would create greater hardship for Defendant. “In the absence of this preliminary relief, it does not appear that the harm to Plaintiff, who has not stated a claim likely to succeed, would outweigh the hardship to Defendants, who would have to cease construction plans, potentially change programming as the result of a loss of fees, and alter a university rule. For similar reasons, it does not appear that an injunction in this instance serves the public interest.” (Ben-Oni v. Wood, n.d., P.5)
Implications
There are no concurring or dissenting opinions associated with this case. As of February 19, 2025, the case remains active, with the Plaintiff expected to submit an amended complaint.
Ben-Oni v. Wood; Docket Number 2:24-cv-02769-DJC-JDP
McLendon is a student at The Citadel in Dr. Kwangho Park’s sports law class (SMGT 555) Law.
References
Ben-Oni v. Wood. (n.d.). United States District Court for the Eastern District of California
October 11, 2024, Decided October 11, 2024, Filed No. 2:24-cv-02769-DJC-JDP
Thomson Reuters (2024, November 18). Ben-Oni v. Wood. Casetext.
http://casetext.com/case/ben-oni-v-wood-2
ASCSUS OPERATING RULES Revised. (2024).
