Inside the Natalie Ryan Lawsuit: Legal Analysis & What’s Next

The case has the potential to have widespread implications in the world of sports.

Natalie Ryan at the 2022 Discraft Great Lakes Open. Photo: DGPT

Last month, Natalie Ryan filed a lawsuit against the PDGA, the DGPT, and 1000 Rated Productions (the host of the OTB Open) regarding the PDGA’s new rules on the eligibility of transgender women to play in the FPO division at elite events. As of now, the PDGA and other defendants in the lawsuit have yet to respond; they are legally obligated to do so by mid-April. Regardless of their approach, the case has potential ramifications not just for disc golf but possibly the broader sports landscape.

The Basics

Ryan’s lawsuit was filed in a U.S. District Court, the initial level of court in the federal legal system. If there is a decision from that court which is appealed up the ladder, then that appeal would be heard in the 9th Circuit United States Court of Appeals (which covers the West Coast), with any further appeals (from a 9th Circuit decision) being heard in the U.S. Supreme Court.

While the case was filed in a federal District Court, Ryan’s claims (at least initially) cover California state (not federal) laws — specifically the Unruh Civil Rights Act, a state law regarding unfair business competition, and a common law business tort claim of “intentional interference with prospective economic advantage.” Plaintiffs are allowed to bring state law cases in federal courts if they satisfy the requirements of “Federal Diversity Jurisdiction,” which generally requires the plaintiffs and defendants to be located in different states and the disputed amount to exceed $75,000. According to Ryan’s filings, she is a citizen of Virginia, and one of the defendants (1000 Rated Productions, the host of the OTB Open) is incorporated and headquartered in California.

As is fairly common in an initial complaint, Ryan’s filing requests a variety of monetary and non-monetary damages, including an injunction that would permit Ryan to play and a declaratory judgment that the policies violate California law. Plaintiffs will also sometimes add additional claims and causes of action as a case develops, or even remove causes of action — which is apparently what happened in an unrelated lawsuit involving Prodigy and Gannon Buhr, where Prodigy dropped their request for an injunction after filing suit against Buhr.

What’s Next

The defendants are scheduled to file a response to Ryan’s complaint by April 11th. At this stage of a proceeding, it would be common for a defendant to reply with a broad, blanket, and almost cursory denial.

Possible Settlement

It’s important to keep in mind that most cases in the US settle outside of court. Even parties that ultimately reach a settlement (and don’t go to trial) will often initiate litigation in an effort to encourage settlement discussions.

Another factor that could push the Ryan and PDGA to consider settlement is that there are not enough legal cases (or direct laws on point) in transgender participation in female sports leagues to confidently predict the outcome of Ryan’s case. Novel legal issues tend to have higher legal uncertainty, sometimes require specialized lawyers, and can end up being more expensive for both sides to litigate.

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  1. Ultiworld Disc Golf Staff
    Ultiworld Disc Golf Staff

    Ultiworld Disc Golf is the premier news media site for the sport of disc golf. Like us on Facebook and follow on Twitter to keep up on all the latest.



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