## Facts

- Tiffany Adams, a 15-year-old freshman at Valley Center High School in Kansas, sought to try out for the school’s interscholastic wrestling team.
- Adams had previously wrestled on the junior high team and had been coached by the same coach who led the high school team.
- After Adams expressed interest in wrestling in high school, some parents and male students objected.
- The school district adopted a policy limiting the wrestling team to boys and refused to allow Adams even to try out, solely because she is female.
- The district asserted justifications including safety concerns, fear of sexual-harassment liability, potential disruption, morality-based objections, and logistical inconveniences (e.g., locker-room arrangements at meets and injury-treatment concerns).
- The district received federal financial assistance, making it subject to Title IX’s prohibition on sex-based exclusion from educational programs and activities, including athletics.
- Adams sued under 42 U.S.C. § 1983 and Title IX, seeking injunctive relief and damages.
- After an evidentiary hearing, the court issued a temporary restraining order requiring the district to allow Adams to try out or discontinue the boys’ wrestling program; the order was extended pending a ruling on a preliminary injunction.

## Issues

1. Whether excluding a female student from trying out for the school wrestling team solely because of sex likely violates the Equal Protection Clause under intermediate scrutiny.
2. Whether the exclusion likely violates Title IX notwithstanding Title IX regulations addressing contact sports.
3. Whether the plaintiff satisfied the requirements for preliminary injunctive relief, including likelihood of success, irreparable harm, balance of harms, and the public interest.

## Decision

- The court granted the preliminary injunction.
- The court found a strong likelihood of success on the Equal Protection claim and at least a substantial likelihood of success on the Title IX claim.
- The court held that the district’s asserted reasons (safety, harassment-liability fears, community objections, disruption, and administrative inconvenience) were unsupported or too speculative to justify a categorical sex-based exclusion.
- The court found irreparable harm from the loss of the opportunity to participate during the wrestling season, which could not be adequately remedied by later money damages.
- The injunction required the district to allow Adams to try out and participate on the same terms as male students or discontinue the boys’ wrestling program.

## Legal Principles

- Sex-based classifications by public schools trigger intermediate scrutiny; the government must show an important objective and a substantial relationship between the sex classification and that objective.
- Generalized assumptions, stereotypes, or community discomfort about gender roles are not sufficient justifications for categorical sex-based exclusions.
- Safety can be an important objective, but speculative risk assessments not tied to evidence or individualized considerations are insufficient to sustain a blanket exclusion.
- Administrative inconvenience and logistical difficulties generally do not justify denying equal access to educational opportunities based on sex.
- For preliminary injunctions, courts consider likelihood of success on the merits, irreparable harm, balance of harms, and the public interest; loss of a season of athletic participation may constitute irreparable harm, and enforcement of constitutional and statutory equality norms serves the public interest.

## Conclusion

The court ordered interim relief because the school district’s boys-only wrestling policy was likely unlawful: it excluded a student from trying out based solely on sex without an adequate evidentiary justification, and the lost opportunity to compete during the season constituted irreparable harm warranting a preliminary injunction.


Adams ex rel. Adams v. Baker, 919 F. Supp. 1496 (D. Kan. 1996)