A sorority at the University of Wyoming Laramie will be forced to admit a male student into its sisterhood after a court rejected a case brought by six female members.
On Friday, U.S. District Alan Johnson granted a motion to dismiss from defendant Artemis Langford, a male UW Laramie sophomore who was admitted to the Kappa Kappa Gamma chapter last year. Johnson ruled that KKG was under no obligation to comply with the definition of “woman” preferred by the six female members who brought the suit.
“The delegate of a private, voluntary organization interpreted ‘woman’, otherwise undefined in the non-profit’s bylaws, expansively; this Judge may not invade Kappa Kappa Gamma’s freedom of expressive association and inject the circumscribed definition Plaintiffs urge,” Johnson wrote in the opinion. “Holding that Plaintiffs fail to plausibly allege their derivative, breach of contract, tortious interference, and direct claims, the Court dismisses, without prejudice, Plaintiffs’ causes of action.”
In the fall of 2022, sorority members were pressured into approving Langford’s initiation, National Review previously reported and the original complaint from March noted. At a meeting to discuss Langford’s candidacy, chapter leaders quashed concerns and encouraged dissenting members to quit the chapter. An online vote was then conducted, asking members to identify themselves with their emails in violation of the sorority’s secret-ballot procedures.
According to KKG policy, Langford could be admitted only by unanimous vote, and chapter leadership was required to disclose the final vote tally. Both of those conditions were violated, as chapter leaders simply announced that Langford had been inducted without confirming that he’d secured enough votes. Langford’s induction had the blessing of national KKG headquarters, which in 2018 issued a “Guide for Supporting our LGBTQIA+ Members,” declaring that the sorority welcomes both “women” and “individuals who identify as women.”
Rather than officially change the organization’s bylaws, which would have required the consent of the board of directors and a two-thirds majority vote at the biennial convention, KKG’s national president simply issued guidance to chapters directing them to admit biological males. This unilateral change to admissions criteria violated long-standing KKG policy, the complaint alleged.
Johnson’s order, which refers to Langford by female pronouns throughout, marks the end of an onerous legal battle between the six sorority members and the KKG organization. The coalition of young women accused KKG of violating its corporate charter and imperiling the safety and historic gender exclusivity of the sisterhood by rubber stamping Langford’s membership.
In June, KKG doubled down on allowing men and asked the court to dismiss the “frivolous” lawsuit, implying that the plaintiffs were motivated by anti-trans bigotry. KKG alleged that the women asked the “Court to insert itself into this controversial political debate and declare that a private organization can only interpret the term ‘woman’ using Plaintiffs’ exclusionary definition of biologically born females.”
The question of whether a transgender woman should be treated as a woman is still subject to interpretation, KKG claimed, given all of the “scholarly articles, political debate, or media commentary” contesting the traditional understanding of womanhood. Rather than affirm the women’s right to membership in a female-only sorority, KKG found them at fault for protesting Langford’s admission.
“Do the Plaintiffs have a legal right to be in a sorority that excludes transgender women?” KKG wrote in the motion. “They do not.”
Langford then filed a memo in support of KKG, alleging that the sorority members intended to “bully” him rather than seek judicial relief. His lawyers argued that he should not have also been named as a defendant in the suit and that the complaint contained excessive factual details, failing to be “simple, concise, and direct” as required by Rule 8 of Federal Civil Procedure.
For example, Langford’s lawyer objected to references to his large physical size, which his lawyer called “insulting jabs,” in the complaint. But those details were key to highlight that Langford’s new gender identity did not negate his overwhelmingly masculine stature, which many of the plaintiffs found intimidating, they wrote in a response.
“Allegations about Langford’s size are not a comment on his physical fitness,” the response from the women read. “These facts, in part, demonstrate the extent to which Langford’s claim of womanhood obscures the actual interactions taking place . . . Biological males like Langford do not become smaller or weaker just because they claim to be a woman. Langford is an individual with physical size unusual for men and unheard of for women.”
The court on Friday said the plaintiffs’ four claims, dealing with subject matter jurisdiction and alleged breach of contract, couldn’t hold up against legal scrutiny.