Samuels v. Barnard College

Background

Justin Samuels, who was representing himself, filed letters that the court treated as a complaint and supplements. He alleged discrimination involving Barnard College’s admissions practices, the Athena Film Festival, the Leadership Incubator, fee waivers, and the Writers Lab. He described himself as a gay Black male and alleged that the festival rejected his script. He sought declaratory relief, injunctions, damages, and other relief.

The court also discussed letters from the U.S. Department of Education’s Office for Civil Rights. Those letters stated that Barnard had changed or clarified certain practices and that the agency had resolved and closed its initial investigation. A later letter stated that the agency was opening an investigation into Samuels’s allegation that Barnard retaliated against him by rejecting his festival submission.

Constitutional claims under Section 1983

The court dismissed Samuels’s claims under 42 U.S.C. § 1983 for failure to state a claim. Section 1983 requires a plaintiff to allege both a violation of a federal right and action taken under state authority. The court found that Barnard College and possibly Columbia University are private institutions and that Samuels had not alleged facts showing that either acted under state authority. The court therefore dismissed the federal constitutional claims under the screening law for complaints filed without paying filing fees.

Title VI and Title IX claims

The court dismissed, for lack of standing and therefore lack of subject-matter jurisdiction, the Title VI and Title IX claims based on Barnard’s admissions policies. Title VI bars covered educational programs from discriminating based on race, color, or national origin, while Title IX bars covered educational programs from discriminating based on sex. The court found that Samuels did not allege that he had applied, or would apply, to Barnard and that the admissions policies had injured him or were likely to injure him. The court treated those allegations as generalized grievances rather than a personally injured claim that a federal court could hear.

The court separately stated that Samuels’s allegations could suggest direct discrimination or retaliation involving the Athena Film Festival, the Leadership Incubator, fee waivers, and the Writers Lab. However, the relief requested appeared directed mainly at admissions practices rather than those alleged injuries. The court also stated that requested injunctions concerning the festival programs might be moot because Barnard appeared to have changed its conduct after the Office for Civil Rights investigation. The court did not finally dismiss these possible discrimination and retaliation claims in this order; instead, it gave Samuels an opportunity to amend.

Leave to amend and remaining claims

The court granted Samuels 60 days to file an amended complaint. It directed him to allege facts showing personal injury, a connection between the injury and Barnard’s or Columbia University’s conduct, and a likelihood that the requested relief would remedy the injury. The amended complaint also had to include facts sufficient to state Title VI or Title IX discrimination or retaliation claims, including facts concerning federal funding and the required elements of each claim.

The amended complaint would completely replace the original complaint and supplements. The court directed Samuels to repeat any facts or claims he wanted considered and to provide information about the relevant people, events, dates, locations, injuries, and relief sought. If he did not timely comply and could not show good cause, the court stated that it would dismiss the remaining Title VI and Title IX claims for lack of subject-matter jurisdiction and decline to consider the state-law claims under supplemental jurisdiction.

The court also certified that an appeal would not be taken in good faith and denied fee-waiver status for purposes of an appeal.