Loggins v. Leland Stanford Junior University

Background

Ameer Hasan Loggins, identified in the complaint as a former Stanford lecturer, sued Leland Stanford Junior University and several individuals. The claims arose from two class sessions on settler colonialism, dehumanization, Israel, and Palestine; Stanford’s investigation into those sessions; Loggins’s suspension with pay during the investigation; Stanford’s public statement about the investigation and suspension; and Stanford’s decision not to extend his teaching contract.

Loggins alleged that he is a Black, African American, Muslim male. During the class sessions, he asked whether Jewish students were present and conducted an exercise involving two students that he said was intended to illustrate profiling and policing. Stanford administrators accused him of antisemitism, investigated his conduct, and suspended him with pay. Stanford later reported that the investigation did not support a finding that he intentionally or objectively discriminated against students, but Stanford and Professor and Senior Associate Dean R. Lanier Anderson declined to extend his contract.

On March 1, 2024, Defendant Feigelis, identified as a Stanford postdoctoral researcher, spoke at a roundtable hosted by the U.S. House of Representatives’ Committee on Education and the Workforce. Loggins alleged that Feigelis called him one of Stanford’s “most racist faculty member[s]” and published an image describing his classroom conduct.

Claims and Motions

Loggins asserted eight causes of action: racial discrimination under 42 U.S.C. § 1981; discrimination under California’s Fair Employment and Housing Act; retaliation under that law; failure to prevent discrimination under that law; retaliation under California Labor Code § 98.6(a); discrimination under Title VII of the Civil Rights Act of 1964; retaliation under Title VII; and defamation.

The Stanford defendants moved under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not state a legally sufficient claim. They also moved under California’s anti-SLAPP statute, a law allowing early challenges to claims arising from protected speech on public issues. Feigelis separately moved to strike the claims against him under the anti-SLAPP statute or, alternatively, to dismiss them under Rule 12(b)(6).

Ruling on Stanford’s Motion to Dismiss

The court dismissed Loggins’s first, second, fourth, and sixth causes of action against Stanford—his § 1981, California Fair Employment and Housing Act discrimination and failure-to-prevent claims, and Title VII discrimination claim—with leave to amend. The court held that Loggins had not alleged facts sufficient to support an inference that his race, color, or religion caused or motivated Stanford’s investigation, suspension, public announcement, or refusal to extend his contract. In particular, the court found that his comparison to Professor Bankman did not show that Loggins and Bankman engaged in similar conduct.

The court dismissed Loggins’s third, fifth, and seventh causes of action against Stanford—his retaliation claims under the Fair Employment and Housing Act, California Labor Code § 98.6(a), and Title VII—with leave to amend. As to the suspension, the court held that objecting to an investigation on the ground that Loggins was not antisemitic was not, as pleaded, opposition to unlawful discrimination or another protected activity. The court also held that Stanford could not have retaliated against Loggins for his lawyer’s October 24, 2023 letter because the suspension occurred before that date. As to the refusal to extend the contract, the court held that the five-month gap between Loggins’s retention of counsel and Stanford’s decision was insufficient by itself to show causation.

The court dismissed Loggins’s second, third, fourth, sixth, and seventh causes of action against the individual Stanford administrators without leave to amend. It held that individuals cannot be sued under Title VII or for discrimination, retaliation, or failure to prevent discrimination under the Fair Employment and Housing Act.

Ruling on Feigelis’s Motion to Strike

The court struck Loggins’s first cause of action against Feigelis, his § 1981 racial-discrimination claim, without leave to amend. Loggins did not allege an actual or proposed contractual relationship with Feigelis, which the court held was required for this claim.

The court struck Loggins’s second, third, fourth, sixth, and seventh causes of action against Feigelis without leave to amend because individuals cannot be sued under Title VII or for discrimination, retaliation, or failure to prevent discrimination under the Fair Employment and Housing Act. The court also struck Loggins’s fifth cause of action against Feigelis, under California Labor Code § 98.6(a), without leave to amend because Loggins could not plausibly allege that Feigelis took an adverse employment action against him.

The court struck Loggins’s eighth cause of action, the defamation claim against all defendants, without leave to amend. It held that Feigelis’s statement was made in connection with a legislative proceeding and therefore was protected under California’s anti-SLAPP statute. The court further held that the statement and its republication in the congressional record were absolutely privileged under California and District of Columbia law. Because that privilege prevented Loggins from showing a probability of prevailing, the court concluded that amendment would be futile.

Disposition

The court granted the defendants’ motions to dismiss and strike. Stanford-related claims against Stanford were dismissed with leave to amend; the specified claims against the individual Stanford administrators were dismissed without leave to amend; and the specified claims against Feigelis, including the defamation claim against all defendants, were stricken without leave to amend. The court set September 20, 2024, as the deadline for any amended complaint and stated that no new defendants or claims could be added without further permission. The order disposed of Docket Nos. 30 and 57.