Quinnipiac Rugby

Quinnipiac Athletes Say Team Downgrade Was Title IX Payback

By Aaron Keller ·

Law360, Bridgeport, Conn. (June 26, 2026, 10:03 PM EDT) -- Quinnipiac University should be stopped from demoting its women's rugby team from varsity to club status because the school seized the earliest opportunity to retaliate against a coach who raised Title IX complaints, current and recruited players told a Connecticut federal judge Friday.

U.S. District Judge Kari A. Dooley said she would issue a written ruling by Tuesday on the athletes' emergency request for a temporary restraining order, declining to immediately rule after a three-day hearing. Following testimony from Quinnipiac's athletic director, its former women's rugby coach and two athletes, the judge said she wanted to review the proper legal standard for causation, which the parties contested.

The judge said she may want to review the parties' arguments about pretext, should she get to that step in the analysis. She reiterated that she had not made a decision.

Arguing for 23 current and recruited players, Lori Bullock of Bullock Law PLLC said Title IX retaliation claims in the Second Circuit are judged under a more relaxed standard than the school argued applies. Citing Papelino v. Albany College of Pharmacy of Union University , a 2011 Second Circuit case, Bullock said retaliation can give rise to a valid Title IX claim if it is one motivating factor behind an adverse decision.

She said Quinnipiac didn't downgrade its women's rugby program until March 14 because it had been unable to do so. First, the school sought to exit a consent decree in Biediger v. Quinnipiac University, another Title IX lawsuit. Once court supervision in that case was lifted on June 30, 2025, university officials "were told not to take any actions after the first year," Bullock said, citing testimony from athletic director Greg Amodio. Quinnipiac announced the rugby downgrade immediately after the team ended its 2025-26 season, she recalled.

"The very first opportunity Quinnipiac had, they cut the varsity team from varsity status," Bullock told Judge Dooley.

No other team was considered for elimination, she argued. Amodio did not make sufficient efforts to promote rugby at Quinnipiac or among other colleges despite the Biediger case mandating the school make good faith efforts to do so, Bullock added.

"It is clear from the outset ... he has not made the necessary efforts to treat women's rugby equally to men's sports or other women's sports," she argued.

Amodio testified the change was necessary because women were overrepresented on Quinnipiac teams, and the university feared a lawsuit by men who did not have equal opportunities. Plus, he said, each university department was forced to cut 6% of its budget due to a drop in enrollment.

Bullock said those reasons were pretext. She argued Quinnipiac really wanted the team gone because its former head women's rugby coach Rebecca Carlson raised repeated complaints about unequal facilities, including a field that was one-third its standard size. A newly constructed baseball field also drained into the rugby field, leaving the women's team playing in mud, Bullock noted.

Quinnipiac would save only $350,000 per year to begin, though its athletic department was asked to cut $1.1 million, Bullock said. Judge Dooley noted the cost savings would increase after the rugby athletes graduated, since the university extended their athletic scholarships even though the team had been downgraded.

Bullock said Quinnipiac downgraded rugby after opting into a $2.78 billion National Collegiate Athletic Association athlete compensation settlement. Sharing revenues and offering name, image and likeness payments to some athletes forced the school to redirect resources away from the rugby team, forcing it to bear settlement opt-in costs, she argued.

Though Quinnipiac said it wanted to focus on remaining competitive in NCAA championships, Bullock noted that some other teams in the Metro Atlantic Athletic Conference did not opt into the settlement. Therefore, not every direct competitor could entice athletes through name, image and likeness or revenue share payments, she said.

According to Bullock, Quinnipiac did not immediately cut the team because doing so could have increased the school's exposure to a lawsuit from Carlson, who testified in earlier Title IX proceedings.

Judge Dooley noted that Carlson offered to resign after an earlier season. Bullock said had Quinnipiac accepted her offer to step down because of struggles related to alleged unequal treatment, it could have been sued for constructive discharge. Cutting the entire team was a less risky move, she argued.

"Coach Carlson's been a thorn in the side of the Quinnipiac University athletic department since 2013, and she made it clear she wasn't going to stop," Bullock said.

The university's $350,000 expense to keep the team running through the 2026-27 academic year is less than the intangible harm to the athletes, she continued. A temporary restraining order would also prevent a "chilling effect" on Title IX complaints, according to Bullock.

According to her, Quinnipiac is saying, "if you complain, your team could be the next to go."

Arguing for the university, Susan D. Friedfel of Jackson Lewis PC said the athletes did not adequately show causation before turning to their pretext arguments. Quinnipiac was not "biding its time with this burning desire" to fire Carlson or demote the team, she said, arguing the athletes were making "four steps of assumptions" to make their case.

The former head coach has raised federal civil rights and Connecticut Commission on Human Rights and Opportunities complaints several times over the years, and though Quinnipiac could have terminated her after every season, it retained her as head coach until it downgraded the team, Friedfel said.

She said it was "incredulous" for the students to argue the university was biding its time to scuttle the varsity program when its entire business is teaching students.

According to Friedfel, but-for causation is the proper standard for establishing Title IX retaliation links. To support her argument, she cited Gagliardi v. Sacred Heart University , a Connecticut federal court case that led to written decisions in both 2019 and 2020 .

Friedfel said Quinnipiac was under no obligation under the Biediger consent decree to advocate for women's rugby after 2016.

Other decisions, such as the university's rationale to join the name, image and likeness settlement, were business decisions on where to best focus resources, she argued. Entering the athlete compensation settlement ensured Quinnipiac would remain competitive, Friedfel said.

"As a business, the university has a right to self-determination," she said.

Though one Quinnipiac women's rugby athlete competed in the Olympics, the team's three national championships occurred roughly a decade ago and came after the school beat only around 10 teams, Friedfel noted. She said the university had a legitimate interest in focusing on NCAA championship sports, where championships require beating hundreds of teams. Rugby is an NCAA emerging sport, with a separate playoff structure governed by the National Intercollegiate Rugby Association, according to testimony.

Reagan Perez, a Quinnipiac athlete who testified during the hearing, said she transferred to the school after her original college cut its rugby team. The sport has been considered emerging for more than two decades, and "it's not on solid ground," Friedfel argued.

Perez and another player, Carolyn Melody, said the team was distraught when it learned it would be downgraded with roughly two weeks left in the spring semester. Melody said she struggled to complete end-of-the-year assignments, and her perfect 4.0 GPA slipped.

Friedfel admitted the college made mistakes in the way it handled the announcement, which occurred after the athletic season — but not the academic semester — had concluded.

"Did they do it perfectly? No," she said. But she said the university did not act with malice and did not engage in gender discrimination.

During a rebuttal, Bullock said Quinnipiac kept women's rugby because of the prior lawsuit, and "when they thought they could get away with it, they got rid of the team."

She noted that her emergency request for a temporary restraining order did not benefit from depositions or other discovery.

Title IX protects students from decisions made "on the basis of s*x," Bullock added. Though the university appears to have brought its men's and women's teams within substantial proportionality of one another, another Title IX requirement, the issue is retaliatory motive, she argued.

Offering her own rebuttal, Friedfel said Quinnipiac responded to many of Carlson's complaints, just as it did with other coaches, depending on available resources.

Friday's oral arguments capped a hearing scheduled for Tuesday, but which spilled into Wednesday and then into Friday.

In a June 5 proposed class action complaint, the athletes alleged Quinnipiac used NCAA revenue-sharing changes, budget pressures and roster management as pretext for downgrading women's rugby from varsity to club status. The proposed class seeks to represent present and future female Quinnipiac athletes.

The women sought an emergency temporary restraining order to preserve the team's varsity status, as well as broader injunctions barring retaliation and requiring the university to administer new athlete compensation and revenue-sharing benefits equitably.

Carlson testified the team had long been treated as "less of a sport." She alleged they were given substandard facilities, limited institutional support and what she described as diminished recognition compared with other championship teams.

Amodio testified that the university needed to reduce women's opportunities and add men's opportunities to better align athletics rosters with shifting student demographics. He also said the overrepresentation of women could leave the institution liable to men who might argue they lack equal opportunities.

The athletes are represented by Lori Bullock of Bullock Law PLLC, and Christine D. Brown and Ben LaCourse of Christine Brown & Partners LLC.

Quinnipiac is represented by Susan D. Friedfel, William J. Rocha and Thomas W. Moyher of Jackson Lewis PC.

The case is Perez et al. v. Quinnipiac University et al., case number 3:26-cv-00898, in the U.S. District Court for the District of Connecticut.

--Additional reporting by David Steele. Editing by Adam LoBelia.

Update!

Quinnipiac Treated Rugby As 'Less Of A Sport,' Judge Told

By Aaron Keller ·

Law360, Bridgeport, Conn. (June 23, 2026, 9:32 PM EDT) -- Quinnipiac University women's rugby athletes and new recruits urged a Connecticut federal judge Tuesday to force the Division I school to maintain the team's varsity status while a Title IX discrimination lawsuit unfolds, arguing the school unfairly targeted the program during budget cuts despite clinching three national titles.

During an all-day hearing on the athletes' bid for a temporary restraining order and preliminary injunction, former head coach Rebecca Carlson testified the team's victories occurred despite repeated hurdles she said other athletic programs did not encounter. For instance, Quinnipiac's rugby field was 15 yards too narrow, leaving her players practicing on turf one-third smaller than regulations required, Carlson said.

The difference "changes everything about how you compete," the former coach testified.

At least one entire season consisted of competitions at other schools, adding significant travel to the athletes' schedules, Carlson added.

When the team first started playing, athletes aimed their car headlights to illuminate the playing surface, she said. The rugby field initially had no benches, and once they were provided, they could fall over backwards into an area that was typically wet, Carlson said.

Other parts of the field were frequently muddy due to construction issues, and visitors to other nearby fields trampled the rugby surface because it wasn't fenced off, she testified.

New baseball and tennis fields were installed on the immediate edge of Quinnipiac's rugby field, causing players to feel even more cramped, Carlson said, at one point describing how she protected her players from other sports teams' stray balls.

Spectators were offered only a few scattered two-person benches, she added. Those who wished to watch games through online streams suffered through announcers who didn't understand rugby and a signal that often cut out because the field wasn't properly wired, Carlson testified.

"Walls were closing in," said Carlson, who exited in May after a 16-year run. "We were being forgotten about," she added.

Carlson accused Quinnipiac administrators of viewing rugby as "less of a sport because we're an emerging sport." The school's three national rugby titles received less recognition compared with Quinnipiac's 2023 men's ice hockey championship, she testified. The hockey team competed in a fully sanctioned National Collegiate Athletic Association tournament, and the women's rugby team, as an NCAA emerging sport, earned National Intercollegiate Rugby Association titles through an end-of-season playoff series that wasn't orchestrated directly through the NCAA.

Carlson filed two civil rights complaints accusing the school of unequal treatment. An investigation revealed no evidence of retaliation, Carlson told Quinnipiac attorney Susan D. Friedfel of Jackson Lewis PC on cross-examination.

Carlson also said the fence separating the rugby field from the baseball field was moved after she complained.

The former head coach was subpoenaed to testify after 16 current players and seven high school recruits filed the Title IX lawsuit June 5. The athletes want U.S. District Judge Kari A. Dooley to immediately block the school from downgrading rugby to a student-run, separately funded club sport while the discrimination challenge progresses.

Barbara Osborne, a University of North Carolina adjunct law professor and sports law textbook author, also testified for the athletes. She said Quinnipiac's program cuts prevented the school from claiming Title IX compliance by showing it was expanding its program offerings, leaving the school no other legal option than to claim its athletic offerings were "substantially proportional" for both men and women.

Osborne said she believed Quinnipiac added women's rugby to become more compliant and criticized what she described as the school's "disingenuous" claim that it wished to focus on NCAA championship sports.

Those opinions drew a rebuke from Friedfel, who challenged Osborne's use of Equity in Athletics Disclosure Act data as the basis for some of her Title IX opinions. Friedfel also said U.S. District Judge Stefan R. Underhill issued a 2013 decision in another case, Biediger v. Quinnipiac University , finding Quinnipiac could not count women's rugby as a Title IX-compliant sport because players did not compete in an NCAA championship tournament, even though the NCAA recognized rugby as an emerging sport.

Friedfel also said women constituted the bulk of Quinnipiac's student athletes, leaving men underrepresented.

Still, Osborne said demoting the rugby team would hurt its players, who she believed would probably not receive the same training, coaching, support and career opportunities typically enjoyed by varsity players. She said schools like Quinnipiac, which joined the NCAA's $2.78 billion athlete revenue settlement, have typically cut programs.

Athletic director Greg Amodio testified that all Quinnipiac departments were ordered to trim 6% of their budgets through a process that began last year. He said the rugby program needed to be downgraded to help the athletic department trim roughly $1.14 million from its $19.2 million budget while adding a $150,000 men's track and field program.

"As it all fell out, we realized we needed to reduce some opportunities and add some opportunities," Amodio testified.

"This was the path that made the most strategic sense," Amodio said, adding that other departments also faced staff and salary cuts. He said his $397,000 base salary was not affected by the belt-tightening measures.

Amodio said the school also needed to calculate revenue sharing and name, image and likeness payments to some student athletes.

But Carlson said she ended the 2025-26 varsity rugby season with a nearly $12,000 surplus. Administrators told her the team was "cash positive," and she said she registered only a $256 deficit in one prior year. Other programs ran larger deficits, Carlson said, but Amodio said some of those deficits were offset by donations.

Carlson blamed the rugby team's demotion on her own Title IX discrimination complaints, accusing administrators of not wanting to deal with making the program equal.

"Ever since I testified, it was a mark that was never going to leave," Carlson said.

Though the hearing was scheduled to conclude Tuesday, testimony will spill into a second day Wednesday. Two student athletes are expected to testify, and Quinnipiac will call Amodio back to the stand, likely as its only witness, its lawyers indicated.

"We're really glad that the judge has been patient," said Lori Bullock of Bullock Law PLLC, who represents the athletes.

The athletes have requested a quick decision, but Bullock declined to predict whether Judge Dooley would rule from the bench Wednesday.

The plaintiffs are represented by Christine D. Brown and Ben LaCourse of Christine Brown & Partners LLC, and Lori Bullock of Bullock Law PLLC.

Quinnipiac is represented by Susan D. Friedfel, William J. Rocha and Thomas W. Moyher of Jackson Lewis PC.

The case is Perez et al. v. Quinnipiac University et al., case number 3:26-cv-00898, in the U.S. District Court for the District of Connecticut.

--Editing by Marygrace Anderson.

Quinnipiac Treated Rugby As 'Less Of A Sport,' Judge Told - Law360 Quinnipiac University women's rugby athletes and new recruits urged a Connecticut federal judge Tuesday to force the Division I school to maintain the team's varsity status while a Title IX discrimination lawsuit unfolds, arguing the school unfairly targeted the program during budget cuts despite cl...