UNITED STATES DISTRICT COURT
DISTRICT OF VERMONT
ALLIANCE OF LESBIAN, GAY, BISEXUAL, )
TRANSGENDERED, AND STRAIGHT STUDENTS ; )
THE WOMEN'S LAW GROUP and THE EQUAL )
JUSTICE FOUNDATION, )
)
Plaintiffs, )
v. )
)
WILLIAM S. COHEN, as Secretary of Defense; )
UNITED STATES DEPARTMENT OF DEFENSE; )
and the UNITED STATES OF AMERICA, )
Defendants.
COMPLAINT
NOW COME the plaintiffs, the Alliance of Lesbian, Gay, Bisexual, Transgendered and
Straight Students, the Women's Law Group and the Equal Justice Foundation, by and through
their attorneys, Blackwood Associates, P.C., and hereby complain against the defendants, William
S. Cohen, as Secretary of Defense, the United States Department of Defense, and the United
States of America, as follows:
1. The Plaintiffs are organizations of students, faculty and staff at Vermont Law
(VLS). They bring this civil rights action to enjoin defendants from subjecting their student
members to unlawful discrimination. The federal Defendants have coerced VLS into acting as
SNIPPETS:
TRANSGENDERED, AND STRAIGHT STUDENTS;)
UNITED STATES DEPARTMENT OF DEFENSE;)
their attorneys, Blackwood Associates, P.C., and hereby complain against the defendants,
The Plaintiffs are organizations of students, faculty and staff at Vermont Law School
They bring this civil rights action to enjoin defendants from subjecting their student
members to unlawful discrimination.
The federal Defendants have coerced VLS into acting as
their agent in an unlawful effort to extend their discriminatory employment policies into
violating the rights of all Vermonters to be free from discrimination based on sexual
Alliance") is an unincorporated association of students, faculty and staff at Vermont Law
concerning discrimination based on sex and gender, and defending the civil rights of women.
whose purposes include education concerning civil rights and inequities
More than ninety percent of VLS students receive some form of federal financial aid,
Pursuant to Vermont and federal law, American Association of Law Schools' policy
employment based on sexual orientation or sex.
discriminate on the basis of sexual orientation or sex.
Under Vermont law, when VLS provides facilities for employment interviews, posts
The United States armed services discriminate in employment on the basis of sexual
1993 authorized regulations that have come to be known as the "Don't Ask,
Other schools with policies like VLS's having barred military recruiters because of
"Solomon-Pombo Amendment", which provides that none of the funds appropriated to
to an institution of higher education that prohibits military recruiting on its campus.
The purpose of this provision is not to meet military needs, but to carry out a political
SPA does not in any case require that military recruiters be granted access to
Dean Wroth stated that this suspension was in response to SPA,
VLS's involuntary suspension of its nondiscrimination policy, under the compulsion of threats
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