Facts

Sunil Kumar and Praveen Sinha were California State University (CSU) professors who practiced Hindu faith and believed that Hinduism requires them to treat all people equally. In January 2023, CSU implemented a revised version of its Nondiscrimination Policy (Policy) which prevents discrimination based on numerous protected characteristics, including "Race or Ethnicity(including color, caste or ancestry)." The Policy does not define "caste." CSU revised the policy based upon input from student, staff, and faculty, and independent recommendation from the Title IX and DHR Policy Revision Workgroup. The Workgroup met at least seven times prior to the Policy's implementation and consisted of nine members, including representatives from CSU's human resources, Title IX compliance, and student affairs departments.

The Workgroup was aware that two stakeholder groups, the California Faculty Association and California State Student Association, both passed resolutions supporting adding caste to Policy. In these resolutions, the groups identified "Brahmins, Kshatriyas, Vaishyas, and Shudras" as the "four main caste groups," identify an oppressed group of people, known as Dalits, who existed entirely outside the caste system. On February 28, 2023, Kumar and Sinha filed the operative First Amended Complaint against Jolene Koester in her official capacity as Chancellor of CSU, seeking a declaratory judgment finding that the inclusion of the word "caste" in CSU's Policy was unconstitutional.

PLAINTIFFS' CONTENTIONS: Plaintiffs contended that defendants violated (1) the First Amendment Free Exercise Clause, (2) the First Amendment Establishment Clause, (3) the Fourteenth Amendment Equal Protection Clause, and (4) the Fourteenth Amendment's Due Process Clause rights, as well as similar claims under the California Constitution. In particular, plaintiffs alleged that the Policy was vague under the Due Process Clause because it used, but did not define, the word "caste." Plaintiffs maintained that use of the word made it impossible to decipher what the policy proscribed because the term "caste" was so expansive. Moreover, plaintiffs argued that the policy impermissibly stigmatized Hinduism and infringed on their religious freedom under the Establishment Clause and Equal Protection Clause by creating an unfair and unfounded association of Hinduism with an oppressive and inhumane caste system that subjected their personal religious beliefs to ridicule.

DEFENDANTS' CONTENTIONS: Defendants asserted that Plaintiffs lacked standing to pursue their claims because they alleged no injury-in-fact and their claims were not ripe - the policy had not been enforced against plaintiffs. On the merits, Defendants argued that the Policy was neutral toward religion and did not burden or interfere with Plaintiffs' exercise of religion, nor did it express hostility towards their religion. Rather, the Policy treated all members of the CSU community equally, barring caste discrimination by anyone (regardless of their religion) and against anyone (regardless of their religion). Additionally, Defendants argued the term "caste" was understandable to persons of ordinary intelligence, and that the Policy provided fair notice of the prohibited conduction - discrimination.

Result

On a motion for judgment on the pleadings, the Court dismissed plaintiffs' federal and state Free Exercise and Equal Protection claims. Following a trial, the Court dismissed plaintiff's federal and state Due Process Clause challenges and entered judgment for defendants on the remaining Establishment Clause claims.