Portz v. St. Cloud State University

Background

The plaintiffs, female student-athletes, sued St. Cloud State University (SCSU) and Minnesota State Colleges and Universities, alleging that SCSU violated Title IX of the Education Amendments of 1972 by discriminating against female student-athletes in athletic participation opportunities, treatment, and benefits.

After a bench trial, the Court entered a permanent injunction requiring SCSU to make participation, treatment, and benefits for female athletes equitable. The injunction required SCSU to file compliance reports every six months. In an earlier proceeding, the Court found that SCSU complied with Title IX’s athletic-participation-opportunities requirement but did not comply with the treatment-and-benefits requirement. The Court reinstated the injunction as to treatment and benefits and required continuing reports.

SCSU later submitted additional reports and moved for relief from judgment, seeking dissolution of the remaining injunction. The plaintiffs opposed dissolution while raising concerns about whether SCSU had provided enough data and evidence showing compliance, including concerns about women’s softball facilities. On August 14, 2024, the Court dissolved the injunction after determining that SCSU was in full compliance with Title IX.

Fee request and parties’ arguments

The plaintiffs requested $51,747 in attorneys’ fees for work performed from SCSU’s February 2023 compliance report through dissolution of the injunction on August 14, 2024. The defendants challenged whether the plaintiffs were still entitled to fees after the injunction was dissolved, but did not challenge the reasonableness of the requested amount.

The plaintiffs had already been determined to be the prevailing parties. The defendants argued that post-judgment work should produce some additional success before fees could be awarded, relying on a decision involving unsuccessful monitoring of an obsolete consent decree. The Court concluded that the cited decision was not binding and did not apply here.

Court’s reasoning

The Court explained that a prevailing party generally keeps that status when later work is closely connected to the issues on which the party prevailed. The Court found that the plaintiffs’ efforts opposing dissolution were closely connected to their earlier success. The plaintiffs did not simply monitor the injunction for their own purposes; the Court repeatedly required them to respond to SCSU’s compliance assertions.

The Court also found that the plaintiffs’ efforts benefited the class by pressing for sufficient data and evidence before the Court determined that SCSU had complied with Title IX. Although the plaintiffs technically lost the final motion because the Court dissolved the injunction, the Court stated that dissolution was the plaintiffs’ ultimate success because it meant SCSU had achieved full compliance with Title IX.

Disposition

The Court held that the plaintiffs remained prevailing parties and that reasonable attorneys’ fees were appropriate. Because the defendants did not challenge the amount’s reasonableness, the Court awarded the full requested amount. The Court therefore granted the plaintiffs’ Final Motion for Attorney Fees and awarded $51,747.00 in reasonable attorneys’ fees. The Court noted that the plaintiffs’ memorandum listed $51,747.50, but treated that figure as a typographical error and used the amount requested in the motion.