Compton v. Alpha Kappa Alpha Sorority, Inc.
| Decision Date | 12 August 2014 |
| Docket Number | Civil Action No. 13–262 RMC |
| Citation | 64 F.Supp.3d 1 |
| Parties | Sandra Compton, et al., Plaintiffs, v. Alpha Kappa Alpha Sorority, Inc., et al., Defendants. |
| Court | U.S. District Court — District of Columbia |
Jon Wyndal Gordon, The Law Office of J. Wyndal Gordon, P.A., Baltimore, MD, for Plaintiffs.
Justin Michael Flint, Laura M.K. Hassler, Eccleston & Wolf, P.C., Lydia Auzoux, Howard University, Washington, DC, for Defendants.
Two members of Alpha Kappa Alpha Sorority, Inc., and their daughters sue the Sorority, alleging that it wrongfully denied the daughters entry into the Sorority's Alpha Chapter at Howard University. Howard University is also a named defendant. Both Defendants have filed motions to dismiss, arguing that none of the Plaintiffs has advanced claims that exceed the amount in controversy required for federal suits between citizens of different states. The Sorority also argues that it did not breach any contractual obligation to Plaintiffs and that all other claims are without merit. Howard contends that it cannot be held liable for the Sorority's actions. For the reasons set forth below, the Court will grant Howard's motion to dismiss and will grant the Sorority's motion in part.
Sandra Compton and Lessie Cofield (collectively, Mothers) are longstanding, active, and proud members of Alpha Kappa Alpha Sorority, Inc., (AKA) the first Greek-lettered sorority established and incorporated by African American college women.1 AKA was founded in 1908 at Howard University in Washington, D.C., to “cultivate and encourage high scholastic and ethical standards, improve the social stature of the race, promote unity and friendship among college women, and keep alive within graduates an interest in college life and progressive movement emanating therefrom.” See Opp'n [Dkt. 32], Ex. 1 (AKA Constitution & Bylaws) [Dkt. 32–3] Preamble. Because AKA was founded at Howard University, the Sorority's Howard Chapter is known as the “Alpha Chapter.” Both Sandra Compton and Lessie Cofield have dreamed for years that their daughters, Laurin Compton and Lauren Cofield, would join AKA's Alpha Chapter. In fact, Lauren Cofield chose Howard University over her first choice, Hampton University, for that very reason. But after a series of unanticipated events from 2009 to 2013, the daughters were not able to realize their dream of becoming Sorors.
Laurin Compton and Lauren Cofield (collectively, Daughters) entered Howard University as freshmen in the fall of 2009.
The Daughters were deemed AKA Legacy Candidates, i.e., “the daughters, granddaughters, adopted daughters or legal wards of an active or deceased [S]oror.” AKA Constitution & Bylaws, Art. IV, § 14. Generally, Legacy Candidates receive preferential treatment over non-Legacy Candidates in the Sorority selection process. For instance, AKA's Constitution and Bylaws provide that Id. (emphasis added). Moreover, with respect to selection priority, AKA's national guidelines provide that:
AKA Mot. to Dismiss [Dkt. 30], Ex. 1 (AKA Undergraduate Membership Intake Process Manual) [Dkt. 30–2] at I–15.
Yet the Sorority also has an interest in maintaining its on-campus presence. Accordingly, AKA balances its preferences for Legacy Candidates and other candidates who can continue AKA traditions throughout their time on a college campus. These dual motivations are best reflected in the Sorority's Legacy Cap provision:
In April or May of 2010, during their freshman year, the Daughters were among a select group of freshmen invited by undergraduate members of the Alpha Chapter to attend AKA's “Ivy Day.” While Ivy Day was primarily intended to honor graduating Sorors, AKA included as part of the event a “base level recruitment mixer ... to influence other undergraduate women to join AKA.” 2d Am. Compl. ¶ 17.
After Ivy Day, however, the recruitment process took an unexpected turn. In 2010, AKA started an unofficial process that involved hazing candidates who wanted to participate in the Membership Intake Process during their sophomore years. Id. ¶ 20. Certain aspects of that process were relatively harmless: candidates were directed to avoid wearing pink and green, the official AKA colors, as well as colors that could be blended to make pink or green. Id. But other aspects of the process were more injurious. For instance, candidates were “commanded to contact random [S]orors daily at a certain hour on the minute, and if they failed to do so, the [candidates] would be forced to suffer and endure verbal abuse....” Id. ¶ 21. The Daughters also recount instances in which candidates were “heckled, harangued, and humiliated ... in front of their peers,” “mentally tormented by [S]orors,” and “restricted from speaking with friends ... and warned not to report abuses.” Id. If a candidate failed to comply with a command, she was disqualified from the Membership Intake Process.
Despite their eagerness to join AKA's Alpha Chapter, Lauren Cofield and Laurin Compton did not participate in the unofficial hazing process in the spring of 2010. Instead, Lauren Cofield reported the hazing to her mother, Lessie Cofield, after Sorority members instructed that she disassociate from her close friends on campus. Lessie Cofield contacted Howard's undergraduate advisor in the summer of 2010, and her concerns were “amicably put to rest.” Id. ¶ 25. Nonetheless, Sorors in AKA's Alpha Chapter learned of Lessie Cofield's phone call.
When Lauren Cofield and Laurin Compton returned to Howard for their sophomore year, they were ostracized by AKA Sorors during official recruiting events and Lauren Cofield was labeled a “snitch.” Id. ¶ 27. The clandestine hazing continued, but the Daughters continued to avoid any involvement in that process. In the spring of 2011, the Daughters learned that the Alpha Chapter was under investigation for its hazing practices, and thereafter, AKA was suspended from recruiting new members for two years. Consequently, the Daughters could not participate in the official Membership Intake Process during their sophomore and junior years of college.
On or about January 26, 2013, AKA notified Howard students that it would be holding a Rush process, i.e., an unofficial meeting for candidates to express interest in the Sorority. Lauren Cofield and Laurin Compton timely completed the general application and the Legacy Candidate application on that day. Id. ¶ 31. In all, AKA received 385 applications from candidates for the Membership Intake Process.2 Twenty-eight of the considered applicants were Legacy Candidates, and seventeen of those Legacy Candidates were sophomores and juniors. The remaining thirty-three considered applicants were non-Legacy Candidates. Id. ¶¶ 32–33.
AKA's Membership Intake Process was governed, in part, by rules adopted by Howard University and the National Pan Hellenic Council (NPHC) at Howard. See AKA Constitution & Bylaws, Art. IV, § 22 (). Howard placed a cap of sixty-five new members on all Greek-lettered organizations. See Opp'n, Ex. 2 (Howard University Student Handbook) [Dkt. 32–4] at 63. However, NPHC's Howard Chapter, of which AKA is a member, imposed a “membership intake limit of no more than fifty (50) selected applicants.” Opp'n, Ex. 4 (NPHC Howard Chapter Constitution) [Dkt. 32–6] at 15. NPHC further mandated that, “[f]or organizations that observe a Legacy Clause[,] no more than 1/3 of selected applicants per intake period shall be legacy applicants.” Id.
Plaintiffs note that AKA is the only Greek-lettered organization on Howard's campus with a Legacy Clause in its Constitution and Bylaws. Plaintiffs contend that NPHC's limitations were not binding on AKA because the Sorority published its own Membership Intake Process Manual that instructs local Chapters with respect to recruiting caps. See AKA Undergraduate Membership Intake Process Manual at I–15. It is undisputed, however, that AKA's Alpha Chapter adhered to NPHC's more restrictive caps during the selection of its 2013 membership intake class.
Plaintiffs allege that “all of the women who elected to participate in the unofficial clandestine ‘hazing’ process were selected for the [Membership Intake Process] at the expense of ... [the Daughters], who followed the Rules, and were thus entitled to participate in the process due to their Legacy status.” 2d Am. Compl. ¶ 34. Plaintiffs further aver that Lauren Cofield and Laurin Compton met all of the necessary qualifications for membership but, in contravention of AKA's Bylaws, the Daughters were subjected to a vote by the Alpha Chapter. Id. ¶ 3 6; see also AKA Constitution & Bylaws, Art. IV, § 14.
On January 30, 2013, Lessie Cofield contacted Constance Pizzaro, AKA's North Atlantic Regional Director, to complain about AKA's selection of...
To continue reading
Request your trial
-
EIG Energy Fund XIV, L.P. v. Petróleo Brasileiro S.A.
...; Grupo Dataflux v. Atlas Global Grp., L.P. , 541 U.S. 567, 570, 124 S.Ct. 1920, 158 L.Ed.2d 866 (2004) ; Compton v. Alpha Kappa Alpha Sorority, Inc. , 64 F.Supp.3d 1, 13 (D.D.C. 2014), EIG Luxembourg's post-suit assignment to EIG Management is ineffective for purposes of this suit.The cour......
-
Bronner v. Duggan
...stage even if it has serious doubts as to the bases for establishing the amount-in-controversy. See Compton v. Alpha Kappa Alpha Sorority, Inc. , 64 F.Supp.3d 1, 14–15 (D.D.C. 2014) (concluding that it was not a "legal certainty" that the plaintiffs could not collect more than $ 75,000, tho......
-
Bronner v. Duggan
...proceedings even if it has serious doubts as to the bases for establishing the amount in controversy. See Compton v. Alpha Kappa Alpha Sorority, Inc. , 64 F.Supp.3d 1, 14 (D.D.C. 2014), aff'd , 639 Fed.Appx. 3 (D.C. Cir. 2016). Even a "cursory" allegation of the amount in controversy, if it......
-
Harris v. Bowser
...police report without converting the District's motion to dismiss into a motion for summary judgment. See Compton v. Alpha Kappa Sorority, Inc. , 64 F. Supp. 3d 1, 12 (D.D.C. 2014).7 Counts I and II do not involve Ms. Liu and the Department of ...