Reges v. University of Washington

Summary

In Fall 2021, Stuart Reges, a principal lecturer in the School of Computer Science and Engineering at the University of Washington, inserted a parody land acknowledgment statement into his syllabus for a required introductory computer science course. His statement read: “I acknowledge that by the labor theory of property the Coast Salish people can claim historical ownership of almost none of the land currently occupied by the University of Washington.” The university removed the syllabus from the course website and condemned the content as “offensive and inappropriate.” The administration also initiated a disciplinary investigation under its anti-harassment and nondiscrimination policies and created an alternate section of the course so students could avoid enrolling in Reges’s class.

On July 15, 2022, Reges filed a federal lawsuit against the University of Washington and its administrators in the United States District Court for the Western District of Washington. He alleged that the university violated his First Amendment rights by retaliating against him for his speech and punishing him based on his viewpoints. He claimed that the university had “effectively stripped him of his primary teaching duties and given him a one-year probationary appointment” in response to his controversial positions, which included his refusal to adopt the university’s Indigenous Land Acknowledgment, an article he wrote entitled “Why Women Don’t Code,” and his participation in an April 2019 “Affirmative Action Bake Sale.” The complaint noted that the university’s investigation relied on broadly worded anti-harassment and nondiscrimination policies, and that administrators had considered Reges’s syllabus “offensive” without providing a clear explanation of any actual disruption to students or classes. The university denied that he had been demoted or placed on probation, stating that “we are revamping the way we manage the intro courses… The duration of Stuart’s latest reappointment will give us an opportunity to evaluate how the transition in management structure and other changes are progressing after one year.”

The district court granted summary judgment to the university, applying the Pickering balancing test and finding that the university’s interest in preventing disruption and maintaining inclusivity outweighed Reges’s speech rights. Reges appealed, and in December 2025, a divided panel of the Ninth Circuit Court of Appeals reversed the district court’s decision. The Ninth Circuit held that Reges’s parody land acknowledgment was protected academic speech on a matter of public concern, stating that public universities cannot discipline professors for “expressing their views, even in a provocative or satirical manner, on matters of public debate.” The court emphasized that student offense alone does not justify retaliation or discipline and remanded the case for further proceedings to determine appropriate remedies, including potential expungement of reprimands or other relief. The appellate opinion also highlighted that the university had not shown any evidence of actual disruption to instruction, student learning, or campus operations resulting from Reges’s syllabus