University of Baltimore Law Review

English-Speakers Only: English as the Official Language of the United States and the Potential Rise in National Origin Discrimination Claims

*Nikkie Navarro

I. Introduction

A Hispanic mother called her local police station after a Chevrolet Avalanche ran over her daughter’s foot.^[1] Neither the mother nor the father spoke English fluently, and the responding officers, who spoke no Spanish, failed to request an interpreter.^[2] The officers refused to provide the parents with the driver’s information and told the father that, if he asked for a report, the officers would show that their injured daughter was at fault.^[3] The family sued the police station on their daughter’s behalf for multiple claims, including Title VI national origin discrimination.^[4]

When the Sixth Circuit Goes Rogue: Bivens v. Zep, Inc. and Title VII Confusion

*Macy Hamlett

I. Introduction

The Sixth Circuit recently decided in Bivens v. Zep, Inc. that an employer cannot be held liable for third-party actions under Title VII of the Civil Rights Act of 1964 unless they “‘intend[ed]’ for the relevant unlawful ‘consequence.’”^[1] The Bivens decision creates a new obstacle for employees to hold their employers accountable for harassment by third parties.^[2] While the Bivens decision seems to come out of thin air, two recent Supreme Court decisions have teed up this outcome to suggest otherwise.^[3] In 2020, the Supreme Court decided Bostock v. Clayton County, which emphasized the intent of employers under Title VII.^[4] Then in 2024, the Supreme Court decided Loper Bright Enterprises v. Raimondo, which empowered Biven’s reinforcement of the Equal Employment Opportunity Commissions (“EEOC”) limited interpretive authority over Title VII.^[5] Bostock emphasized that when an employer intentionally treats an employee worse because of their membership in a protected class, Title VII is violated.^[6] Further, Loper Bright highlighted that agency interpretations of statutes, such as those by the EEOC, should no longer be treated with deference.^[7] Combined, these decisions laid the foundation for the Sixth Circuit’s rationale in Bivens.^[8]

Transgender Athletes’ Rights and Opportunities: Idaho Tests the Bounds of the Supreme Court’s Transgender and Heightened Scrutiny Decisions.

*Meaghan Slattery

I. Introduction

On July 3, 2025, the U.S. Supreme Court granted certiorari to hear Little v. Hecox to decide on the issue of “[w]hether laws that seek to protect women’s and girls’ sports by limiting participation to women and girls based on sex violate the equal protection clause of the Fourteenth Amendment.”^[1] The case may establish a definitive level of scrutiny for courts to apply to legislation affecting transgender individuals, specifically transgender athletes.^[2]

The TAKE IT DOWN Act’s 48-Hour Deadline: What Does It Mean When Section 230 Still Shields Platforms?

*Tyler Konigsberg

I. Introduction

Artificial intelligence has made it possible to generate fake but realistic intimate images from ordinary photographs.^[1] These “deepfakes” spread quickly through social media and private messaging, leaving victims little ability to stop their circulation.^[2] The images cause severe harm, and platforms often fail to stop them.^[3] Schools across the country are now experiencing this crisis firsthand.^[4] As of 2023, up to 98% of deepfake videos online contain sexually explicit intimate depictions.^[5]

From Courtroom to Locker Room: The House Settlement and the Changing Game of College Athletics

*Hassan Ahmed

I. Introduction

On June 6, 2025, United States District Judge Claudia Wilken issued an order granting the final approval of the settlement agreement in College Athlete NIL Litigation.^[1] This long-awaited settlement brings a resolution to three consolidated antitrust cases against the National Collegiate Athletic Association (“NCAA”): House v. NCAA, Oliver v. NCAA, and Carter v. NCAA^[2] (collectively referred to as the House settlement). These lawsuits, brought by student-athletes, alleged that the NCAA rules barred or restricted them from receiving compensation in exchange for the use of their name, image, and likeness (“NIL”), in clear violation of the Sherman Antitrust Act.^[3]