A former assistant women’s volleyball coach for San José State University on Oct. 13 filed a renewed lawsuit alleging that her dismissal for raising concerns about a transgender player constituted sex discrimination and a violation of the First and 14th Amendments.
The plaintiff in Batie-Smoose v. The Board of Trustees of the California State University, a Christian who “holds a sincere religious belief that God created human beings male and female,” opposed the inclusion of the player on the team’s roster. In 2024, she filed a complaint and request for investigation with SJSU’s Title IX office and other officials, after which she was suspended. SJSU declined to renew her position in 2025.
Initially, the plaintiff filed her lawsuit against SJSU and other defendants in the U.S. District Court for the Central District of California in September 2025. But months later, a federal judge granted the defendants’ motion to transfer the case’s venue to the court’s Northern District.
The plaintiff said she learned of the player only a short time after she began her employment at SJSU in 2023. The team’s head coach allegedly confirmed the player was transgender to the plaintiff, warned her not to disclose this to players, recruits, families or staff and said she would be terminated if she did so.
The plaintiff then began to raise concerns, telling the head coach that she “could not in good conscience treat a male athlete as female.” She also became concerned that SJSU’s treatment of the player, compared to other female athletes, may have constituted sex discrimination under Title IX.
After a series of April 2024 news articles publicized that the player was transgender, the plaintiff alleged that SJSU assigned its assistant athletic director of diversity, equity and inclusion to “monitor” her and ensure that she did not discuss the issue. She further alleged that similar monitoring was not imposed on other coaches.
In September of that year, a co-captain of the team joined a lawsuit against the team’s conference alleging violations of Title IX. The plaintiff said she again spoke up to the head coach about her concerns, only to be told that raising the issue further could result in her termination. She submitted her Title IX complaint shortly thereafter and allegedly disclosed the complaint to the media.
SJSU acknowledged receipt of the complaint and requested a meeting with the plaintiff. However, the plaintiff alleged that this meeting did not occur until after she had been removed from the volleyball program and placed on administrative leave. SJSU sent the plaintiff a notice that her position would not be renewed while the Title IX investigation was pending.
SJSU referred HR Dive to the California State University system for comment. Cal State declined to comment.
In a memorandum submitted in 2025 as part of the plaintiff’s original lawsuit, SJSU argued that the plaintiff’s claims failed as a matter of law because the allegations revealed that the university had a non-discriminatory and non-retaliatory motive in suspending her.
Among other bases, SJSU said it had done so because the plaintiff disclosed personally identifiable information about the player, an act it claimed violated the Family Education Rights and Privacy Act of 1974. The plaintiff disputed this finding in her complaint, claiming that the information she disclosed “was from public or personal knowledge” rather than FERPA-protected.
In January 2026, the U.S. Department of Education’s Office for Civil Rights published its finding that SJSU violated Title IX in part by subjecting the plaintiff to disparate treatment in employment on the basis of sex. It noted that SJSU suspended the plaintiff for her alleged FERPA violations but did not similarly suspend the head coach, who discussed the matter with the media.
The legal saga has led to a variety of related litigation, including an ongoing lawsuit filed against the Trump administration by Cal State challenging the former’s threat to withhold federal funding over the latter’s inclusion of transgender athletes.
It is also part of a broader shift at the federal level with respect to the occasional clash between employees with sincerely held religious beliefs and the concept of gender identity. The U.S. Equal Employment Opportunity Commission has been at the center of that shift. Earlier this month, EEOC described as accommodations conduct that its Biden-era counterpart once classified as discriminatory towards transgender people.
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