Nat’l Wrestling Coaches Ass'n v. U.S.

Dep't of Education
District of Columbia Court of Appeals
883 F.2d 93 (D.C. Cir. 2004)

Key Search Terms: Three-part test, standing, adequate remedy, “better

odds,” adverse effect of Title IX on male athletes

Facts
The National Wrestling Association, the Committee to Save Bucknell Wrestling,
the Marquette Wrestling Club, the Yale Wrestling Association, and the College
Sports Council (Apellants) are membership organizations formed to represent
the interests of collegiate men’s wrestling coaches, athletes, and alumni. The
Apellants brought this action for declaratory and injunctive relief alleging
injury caused by the elimination of men’s varsity wrestling programs at various
universities. The Appellants’ main contention is that the Three-Part Test of
Title IX violates the equal protection component of the Due Process Clause of
the Fifth Amendment because it requires “the same intentional discrimination
that Title IX prohibits.” The District Court granted the Department’s motion to
dismiss for lack of standing by Appellants and this appeal followed.

Issue
Whether the Appellants have alleged an injury in fact that more than likely will
be redressed by a favorable decision to satisfy the standing requirement under
Article III.

Holding
The Appellants have the burden of proving (1) at least one of its members
would have standing to sue individually, (2) the interests the group seeks to
protect are germane to its purpose, and (3) the relief requested does not require
the involvement of an individual member of the association in order for the
National Wrestling Association to sue on behalf of its members. It is
“substantially more difficult” for a plaintiff to establish standing when the
“alleged injury arises from the Government’s regulation of a third party that is
not before the court.” The court was not convinced that granting the relief
asked for by the Appellants would remedy the injuries alleged. The court
reasoned that nothing in the Three-Part Test requires schools to eliminate or
cap men’s wrestling programs and noted that the Appellants conceded that if
the court grants the requested relief it will not necessarily impact any of the
schools’ decision to cut the men’s wrestling program. The court reasoned that
a judgment that would only provide “better odds” of remedying the alleged
injury in fact is not close to satisfying the redressability requirement of Article
III. The court held that Appellants lack standing under Article III and in the
alternative, even if that requirement had been met, the case would be barred by
the “adequate remedy” limitation.
Summarized by: Reid Murtaugh