A federal judge from the Eastern District of Tennessee has dismissed the claim of a high school athlete, who claimed her due process rights were violated when her high school basketball coach kicked her off the team “without a hearing,” which she alleged caused a college to rescind an offer for a full athletic scholarship.
The plaintiff in the case was Sable Winfree, a student at Warren County High School and, at the time, a member of the women’s basketball team.
The incident occurred on November 15, 2023, when Mendy Stotts, the women’s basketball coach and an individual defendant in the case, pulled the plaintiff out of practice to speak with her in the hallway. Stotts, allegedly, “yelled” at the plaintiff, “saying she was tired of the plaintiff’s disrespect towards her” and then accused the plaintiff of calling her the “f-word” during practice. She went on to tell her that she “no longer wanted her as part of the basketball team.” That same night, the plaintiff emailed Phillip King, one of the school’s athletic directors, to request a meeting.
At the time of the incident, Winfree had been offered a full scholarship to play basketball at Trevecca Nazarene University.
The following day, the plaintiff and her mother met with King and Assistant Principal Anna Geesling to discuss the incident. The plaintiff’s mother explained that she had never heard about any disciplinary proceedings prior to the plaintiff being kicked off the team, according to the complaint. Another meeting was held the next day, this time with King, Principal Chris Hobbs (also a co-defendant), Stotts, the plaintiff, her parents, her grandparents, and a family friend. At the meeting, Stotts said she had evidence that the plaintiff said “the f-word,” while the plaintiff stated that there were witnesses who would testify that she did not say the “f-word,” according to the complaint. However, the plaintiff was not allowed to present those witnesses. At the end of meeting, Stotts dismissed her from the basketball team. Hobbs upheld Stotts’ decision. Two weeks after the plaintiff was dismissed from the team, Trevecca Nazarene rescinded the scholarship offer. The plaintiff alleged she also “had anticipated” scholarship offers from Middle Tennessee State University and Tennessee Tech University, but these offers never came.
On April 4, 2024, the plaintiff sued, alleging that the defendants violated her due process rights by dismissing her from the team without a hearing and defamed her by falsely stating that she had said “the f-word.” The defendants subsequently moved for judgment on the pleadings, pursuant to Rule 8 of the Federal Rules of Civil Procedure, which requires that a complaint contain “a short and plain statement of the claim showing that the pleader is entitled to relief.”
In its analysis, the court considered whether students have a property interest in playing on a school sports team “when they are faced with suspension or removal from their respective teams, and that removal results in the student-athlete losing one or more athletic scholarships to colleges or universities.”
The court noted that in order to establish a due process claim, the plaintiff must show that she has “been deprived of a life, liberty, or property interest.” Tomaszczuk v. Whitaker, 909 F.3d 159, 164 (6th Cir. 2018) (quoting Ashki v. INS, 233 F.3d 913, 921 (6th Cir. 2000)).
The instant plaintiff pointed to a handful of “non-binding cases where courts have found a property interest in participation in school sports,” according to the court. “This is hardly a deep bench of cases, and, regardless, the plaintiff’s argument runs afoul of binding precedent. While the court recognizes the practical impact that a scholarship offer often has on the ability of a student to obtain a higher education, it does not have the discretion to ignore the weight of binding precedent.” Ultimately, the court ruled that since the plaintiff “does not have a due process interest in continued participation in school sports, her due process claim must be dismissed.”
The court next turned to the plaintiff’s state-law defamation claim, in which she argued that the defendants defamed her by falsely alleging that she said the “f-word.”
“Because the claim over which the court has original jurisdiction has been dismissed, the basis for the court’s original jurisdiction is extinguished,” the court noted. “The court finds that the interests of judicial economy and abstaining from needlessly deciding state-law issues weigh in favor of declining to exercise supplemental jurisdiction over the remaining state-law defamation claim.”
Sable Winfree v. Warren County School District, et al.; E.D. Tenn.; Case No. 4:24-cv-35; 7/29/24
