WILLIAMSPORT - Court documents filed last week break Line Mountain School District's silence in the federal lawsuit filed by the parents of a female student who has been told she can't participate in the district's all-male wrestling program.

In statements, Superintendent Dave Campbell, three board members and two wrestling coaches say they are protecting seventh-grade student Audrianna Beattie and male athletes from potentially awkward situations and sexual contact during wrestling practices and matches, psychological scarring and inevitable injury and defeat of female wrestlers.

Brian and Angie Beattie, parents of Audrianna, filed the lawsuit last month in the U.S. District Court for the Middle District of Pennsylvania on behalf of their daughter who was not allowed on the wrestling program because it's gender-specific.

Safety a priority

The district's 65-page response was filed Nov. 8 by attorney Chris Conrad, of Marshall Dennehey Warner Coleman & Goggin in Camp Hill.

In the documents, Campbell said the safety and welfare of district students are the administrators' top priority.

"Under tort principles of negligence, educators owe students a duty to anticipate foreseeable dangers and to take reasonable steps to protect those students from that danger," he said. "To this end, educators owe the same degree of care and supervision to their students that reasonable and prudent parents would employ in the same circumstances for their children."

As superintendent, a former wrestling coach and a father of four athletic girls, Campbell said it is in the best interest of all involved to avoid potential and foreseeable "social, mental and moral dilemmas as a result of daily practices given the clear anatomical differences between adolescent males and females."

Board President Troy Laudenslager - a father of two, a former wrestler and coach and a state wrestling champion - said educational opportunities must be provided in a safe environment free of sexual harassment and misconduct.

Due to the continual, close physical contact involved in wrestling, the activity merits separation between males and females, Laudenslager said.

"There are clear and present anatomical differences between males and females, especially when individuals reach the age of puberty," he said. "Therefore, in an effort to promote students safety, all students have an equal right to be protected from any undesired contact of sensual body parts from a person of the opposite sex."

By forcing students to wrestle co-ed, Laudenslager said those students would be required to "lower their moral standards and expose them to indecent contact from a member of the opposite sex."

Significant safety concerns also arise when people of the opposite sex in a different weight classes because one has a "superior size and strength," he said.

Changes in strength

Director Ron Neidig, elementary wrestling coach, said Audrianna is a dedicated wrestler who ended her season with a record of five wins and three losses.

However, he said, a match between her and a boy in her weight class who was clearly stronger and more physical did not end in her favor.

Although Audrianna was not seriously injured, Neidig said, "I could tell from her tears that she was in pain and emotionally hurt. The thought of knowing how bad this match could have turned out is sickening. My biggest concern with wrestling is making sure our children do not get injured, boy or girl."

In wrestling, Neidig said there is not a big weight difference between opponents, but boys tend to be stronger.

"In my personal experience, however, as children grow, boys become much stronger and more physical than girls and the risk for injury becomes higher for a girl when she wrestles a boy through junior high and high school," he said.

The district's stance is protecting male and female athletes from long-term "psychological ramifications," said Director Lauren Hackenburg, who has two sons on the wrestling team.

"By allowing a female on the male wrestling team, we could be promoting the onset of social phobias, which would have long term implications for the males and would wrestle a female and vice versa. This situation can create psychological confusion and stress," she said.

Close contact

Many of the wrestling moves involve close contact, which presents "real appreciable dilemmas well beyond mere inconvenience for the district," said Campbell.

If Audrianna is permitted to wrestle on the male team, the coaches and male students ranging in age from 12 to 15 will be forced to practice techniques with her that involved contact that is considered "immoral and possibly illegal, given that the participants are minors," Laudenslager said.

Campbell wonders: If a child refuses or the parents refuse to allow that child to practice these moves on the opposite sex, will that child be allowed to be a part of the team or will that child be penalized?

Laudenslager said, given the differing anatomical parts of boys and girls, co-ed participation would force all participants to "think it is acceptable for a person of the opposite sex to touch them in sensual areas and vice versa. If the physical contact of the opposite sex is undesired and felt to be morally unacceptable, an individual would be forced to lower their moral standards and be subjected to sexual harassment."

Co-ed wrestling would "not only provide an opportunity to illegally touch the sensual parts of the opposite sex, but an excuse," Laudenslager said.

Furthermore, he said, the inevitable contact with adult male coaches would be "inappropriate and illegal, especially with a minor."

"The environment would groom children into thinking contact with their sensual body parts by adults and other adolescents of the opposite sex is normal and just wrestling," Laudenslager said. "It would also facilitate an opportunity for contact to be taken to the next level without anyone being able to notice what is going on."

Such contact could be considered groping, sexual harassment or potentially deviate sexual intercourse if it is unwelcome or causes a sexual response for either person, he said.

Lainey Martz

While Audrianna participated in a youth wrestling program for students up to sixth grade, Campbell said the program was not a school-sponsored activity and the organization only used district facilities with its own rules and regulations.

Her concerned parents stated that "they felt without practice, she could lose out on potential college opportunities," Campbell said. "I specifically asked if they felt not competing against boys would have a negative impact for future opportunities of wrestling for a female collegiate team. They implied they were not sure."

He sent an e-mail to the Beatties in April asking if there was a possibility of another female student willing to wrestle in order to allow her a partner, but they never responded, he said.

"If there was truly an interest, the district would sponsor and maintain a female wrestling team, as was the case as recently as the 2006-07 wrestling season," Campbell said.

The district stated in the court documents that a female wrestler acted as a team manager and was allowed to participate on the boys team by taking forfeits at 103 pounds and to wrestle any female wrestlers at that weight class. She was not allowed to practice with the male wrestlers.

That wrestler was Lainey Martz, and according to The News-Item archives, she did wrestle a boy, and won. Martz pinned Pat Welker in 47 seconds during a match against archrival Upper Dauphin to win the Tri-Valley League championship in January 2007.

Girls' team?

The superintendent said Audrianna would still have opportunities outside the junior high wrestling team to practice, but the Beatties have not taken any steps to discuss alternative accommodations.

Head varsity wrestling coach Mark Martz, distantly related to Lainey, and head junior high wrestling coach Darin Keim said they are not comfortable demonstrating wrestling moves on a female participant and it would be inappropriate to supervise required showers after practices.

Martz said he is not against female participation if they have a female practice partner and only participate in women's wrestling tournaments.

"I do not want to lose male wrestlers from our team, and I have serious concerns that no one will want a female practice partner," he said. "Furthermore, this will be detrimental to the psyche of our male participants."

The situation will raise issues of sexual harassment, he said.

"The female and male physical body characteristics are very different and a female participant is in danger of getting physically hurt by a male participant," Martz said.

Keim said he's concerned about Audrianna being hurt.

"I think if she were to wrestle girls, the probability of injury would be lessened," Keim said.

Sex discrimination

The Beatties say the district is discriminating against their daughter on the basis of sex in violation of the Equal Protection Clause of the 14th Amendment of the U.S. Constitution and the Equal Rights Amendment of the state constitution.

By denying the girl participation, they said she would have missed opportunities to practice and compete, which would cause her to fall behind in her development as a wrestler and prevent her from being able to compete in the future.

The district's brief in opposition, also filed Nov. 8, reiterates the points made by the Campbell, the school board directors and the coaches and states here is no merit in the temporary restraining order.

Nineteen cases were listed and described to support the district's defense.

The districts accused the Beatties of waiting until the eve of the wrestling season to file the action in order to manufacture a false sense of immediacy, urgency and irreparable harm if Audrianna is not allowed on the team.

A federal judge ruled Nov. 1 that Audrianna is allowed to participate in the wrestling program until the suit is settled. Campbell confirmed this week the district is following the order.

A hearing for preliminary injunction is set for 10 a.m. Wednesday in Courtroom 3 at the Herman T. Schneebeli Federal Building and United States Courthouse, 240 W. Third St., Williamsport, in front of U.S. District Judge Matthew W. Brann.

The News-Item requested a list of the costs associated with defending the lawsuit on Nov. 4 but received no response. Before the school board meeting Tuesday, Campbell passed the question onto Business Manager Phil Rapant, who in turn said the request was sent to solicitor Rich Roberts to determine whether the information could be released. Roberts was not at the meeting and could not be contacted Friday.

A Right to Know Request was submitted to Campbell, the district's RTK officer, at approximately 4 p.m. Friday. The district has five business days to respond to the request.