Jelani Gardner is a former professional basketball player and experienced coach. In April 2023, Gardner signed a four-year employment agreement with Sage Ridge School, a private school in Reno, Nevada, to serve as Assistant Athletic Director and Head Boys’ Basketball Coach. He alleged that, during recruitment, he informed the School of his kidney disease and need for dialysis. According to the complaint, Sage Ridge agreed to accommodate his condition by permitting him to work remotely when necessary. Gardner alleged that during the recruitment process, the Head of School discussed with him the School’s “racial quota” of 80% white students and 20% black students, which would “facilitate community acceptance of the basketball team and of Gardner, as a black male.”
Shortly thereafter, Gardner relocated to Reno with his son, J. Doe, who was entering the ninth grade and was subsequently enrolled at Sage Ridge.
Almost immediately after enrolling, Doe allegedly encountered a racially hostile environment at Sage Ridge. As one of very few Black students on campus, he claimed he was treated differently by both peers and faculty. According to the complaint, this culminated during a school field trip when Doe was separated from the other students, placed in an isolated cabin, and subjected to surveillance and restrictions that were not imposed on his white peers. He was later accused of making inappropriate comments and gestures, which Doe denied. Doe alleged that these accusations were false or exaggerated, and that similar or more serious behavior by white students went unpunished. Following the field trip, Doe was suspended and, upon his return, received no academic support or structured plan to reintegrate. The School ultimately expelled him, which the family alleged was racially motivated and inconsistent with how other students were treated.
Gardner claimed that his son’s treatment had a direct impact on his employment. After he raised concerns about the field trip incident and the investigation that followed, he alleged that School leadership instructed him to stop speaking out and to apologize to the families of the white students involved. Gardner was removed from his office, relieved of his assistant athletic director duties, and soon thereafter terminated. Gardner alleged that during his time at the School, the Head of School made racially insensitive remarks, including asking him what “Black people want to be called these days.”
Plaintiffs filed suit alleging twelve causes of action under federal and state law, including race discrimination, disability discrimination, retaliation, and emotional distress. They claimed that Sage Ridge failed to protect students from race-based harassment and punished both Gardner and Doe in retaliation for speaking out.
The Court reviewed the School’s motion to dismiss and issued the following rulings:
Title VI and Title IX Claims
Plaintiffs alleged that both Gardner and Doe were subject to discrimination prohibited under Title VI (race) and Title IX (sex) because Sage Ridge, a 501(c)(3) nonprofit, received a Paycheck Protection Program (PPP) loan and had federal tax-exempt status. The Court rejected these arguments at the threshold. The Court explained that tax-exempt status does not involve the receipt of federal financial assistance and therefore does not subject a private school to Title VI or Title IX obligations. Although Sage Ridge did receive a federal PPP loan, the Court found the timing dispositive: the loan was received and forgiven in 2020, and the events underlying the lawsuit occurred in 2023. Because the plaintiffs did not allege a more recent receipt of federal funds or demonstrate a nexus between the loan and the alleged discriminatory acts, the Court held that Sage Ridge was not a covered entity. The Court dismissed these claims.
Title VII and State Law Discrimination Claims
Gardner’s Title VII and Nevada fair employment claims alleged race-based discrimination but failed to differentiate among distinct legal theories, such as disparate treatment, hostile work environment, and retaliation. The Court explained that these theories have separate legal standards and must be pled with clarity. Lumping them together in a single cause of action made it difficult to assess whether the facts supported any one of them. However, because the defects were procedural rather than substantive, the Court allowed Gardner to amend and re-plead these claims in a more specific manner.
Retaliation Claims
The Court gave significant weight to Gardner’s allegations that his termination closely followed his internal complaints about the race-based mistreatment of his son. It recognized that opposing discrimination against others, particularly close family members, may qualify as protected activity under Title VII, Section 1981, and state law. The Court also acknowledged that temporal proximity between protected activity and adverse action is often sufficient at the pleading stage to support an inference of retaliation. Here, Gardner alleged that he was told to stay quiet, that his responsibilities were stripped, and that he was terminated shortly after advocating for his son. Those allegations, the Court held, plausibly supported retaliation claims under all three statutes.
Americans with Disabilities Act (ADA) Claim
Gardner alleged that Sage Ridge failed to accommodate his kidney failure and retaliated against him for requesting accommodations. However, the Court dismissed the ADA claim because the complaint did not clearly distinguish among three separate legal theories: (1) failure to accommodate, (2) disability-based discrimination, and (3) retaliation. Each of these claims involves different legal elements, and the Court found that Gardner’s complaint did not give sufficient notice of what theory was being pursued. Nonetheless, the Court gave leave to amend, noting that Gardner had described a medical condition and some facts suggestive of an accommodation process.
Intentional Infliction of Emotional Distress
Both plaintiffs alleged emotional harm resulting from their experiences at Sage Ridge. Doe described racial isolation, forced apologies to white families, exclusion during school trips, and ultimately expulsion. Gardner claimed he was subjected to degrading treatment, including racially insensitive remarks by administrators, and being fired after raising concerns. The Court acknowledged that emotional distress claims require allegations of “extreme and outrageous” conduct. While courts are often hesitant to allow these claims to proceed, the Court here found that the alleged pattern of race-based mistreatment, combined with the alleged retaliation and disparaging comments, was sufficient to allow a jury to determine whether the conduct was legally actionable.
Negligent Supervision and Retention
Gardner’s claim that the School negligently supervised or retained personnel was dismissed due to a lack of factual support. The complaint did not allege that the School had prior knowledge of any employee misconduct or failed to respond appropriately. The Court explained that Nevada law requires a showing that the employer knew or should have known of the employee’s unfitness. Because the complaint did not meet that standard, the claim was dismissed with leave to amend.
The Court ultimately dismissed five of the twelve claims, and allowed the retaliation and emotional distress claims to proceed.
Gardner v. Sage Ridge Sch. (D.Nev. June 17, 2025) 2025 U.S.Dist.LEXIS 114896.
Note: This case highlights the range of legal claims a school may face following an employee termination and student expulsion, and the nuances that can arise when an employee is also a parent at the school. LCW will continue to monitor this case for more developments.