## Facts

- A group including the plaintiffs, former Stanford University students, entered a Stanford classroom during a scheduled quiz in an electrical engineering course taught by Professor William Shockley.
- The group’s purpose was to protest Shockley’s views on genetics and to demand that he debate another person publicly.
- Shockley told the group they were interrupting a quiz and ordered them to leave; the group refused.
- Shockley asked the demonstrators to identify themselves; they refused.
- A member of the group read a statement at the front of the room while another distributed copies; the event lasted about thirty minutes.
- The quiz could not be administered as scheduled because of the protest activity.
- Stanford charged plaintiffs in writing with violating its Policy on Campus Disruption by disrupting a university function or activity.
- A hearing officer found the students knowingly intruded into the class, and Stanford’s president imposed indefinite suspensions.
- Plaintiffs sued university officials under 42 U.S.C. §§ 1983 and 1985, alleging violations of the First, Fifth, Eighth, Ninth, and Fourteenth Amendments, seeking injunctive relief and damages.

## Issues

1. Whether Stanford and its officials acted under color of state law such that constitutional claims and claims under 42 U.S.C. §§ 1983 and 1985 could proceed.
2. Whether disciplining students for entering and interrupting a class during a quiz violated the First Amendment.
3. Whether the Policy on Campus Disruption was unconstitutionally vague or overbroad as applied to plaintiffs’ conduct.
4. Whether the disciplinary procedures provided constitutionally sufficient due process (assuming state action).
5. Whether plaintiffs stated viable claims under the Fifth, Eighth, and Ninth Amendments and § 1985 based on the record.

## Decision

- The court granted defendants’ motion for summary judgment and dismissed the action.
- The court found no sufficient state action nexus to treat Stanford’s disciplinary decisions as action under color of state law for §§ 1983/1985 and Fourteenth Amendment purposes.
- The court held that the protest conduct materially disrupted an academic activity and could be disciplined without violating the First Amendment.
- The court rejected vagueness and overbreadth challenges to the disruption policy as applied to the concrete interference with a class and quiz.
- The court concluded that plaintiffs received adequate notice and a hearing before discipline and, in any event, had not shown a federal constitutional violation.
- The court rejected Fifth, Eighth, Ninth Amendment theories and found the § 1985 conspiracy claim unsupported.

## Legal Principles

- Liability under 42 U.S.C. § 1983 requires action under color of state law; private university discipline is not state action absent a sufficient nexus with the state.
- The First Amendment does not protect conduct that materially disrupts a class or prevents the administration of a scheduled academic activity.
- A university regulation barring disruption of university functions is not unconstitutionally vague or overbroad when applied to actual obstruction of classroom activities rather than mere advocacy.
- Procedural due process, if applicable, is generally satisfied in academic discipline by written notice of charges and an opportunity to be heard before sanctions are imposed.
- The Fifth Amendment constrains federal action, the Eighth Amendment does not govern ordinary university disciplinary sanctions, and the Ninth Amendment does not supply an independent basis for relief on these facts.
- A § 1985 claim requires a viable underlying deprivation of federal rights and evidence of an actionable conspiratorial agreement.

## Conclusion

The court upheld Stanford’s indefinite suspensions for a classroom protest that prevented a quiz from being administered, ruled that the disruption policy was valid as applied, and granted summary judgment because the discipline did not amount to a federal constitutional violation and was not action under color of state law for §§ 1983 or 1985.


Furumoto v. Lyman, 362 F. Supp. 1267 (N.D. Cal. 1973)