Phillip v. University of Rochester
United States Court of Appeals for the Second Circuit
316 F.3d 291 (2d Cir. 2003)
Nigel Phillip, Grant Gittens, Bernard Schmidt, and St. Patrick Reid (plaintiffs) were African American students who attended the University of Rochester (defendant). The University of Rochester was a private university. One night the plaintiffs and other students, many of whom were minorities, were socializing in the lobby of the university’s lobby. A university security officer (defendant) told the students to leave. The officer then demanded to see Gittens’s university identification. After seeing Gittens’s ID, the officer grabbed the ID and radioed the Rochester Police Department for backup. Additional university security officers arrived. Phillip attempted to leave with Gittens, but the officer blocked the car’s exit. The police officers arrived and arrested the plaintiffs. The plaintiff spent the night in jail before being released. All charges against them were dropped. The plaintiffs sued the university and two university security officers for, among other things, violating the equal benefit clause of 42 U.S.C. § 1981. The defendants moved to dismiss. The trial court granted the defendants’ motion in regard to the § 1981 claim because the plaintiffs failed to allege state action. The plaintiffs appealed.
Rule of Law
Holding and Reasoning (Pooler, J.)
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