Phillip v. University of Rochester

African American students Phillip, Gittens, Schmidt, and Reid (plaintiffs) were socializing with other minority students in a University of Rochester (private university, defendant) lobby when a university security officer confronted them, grabbed Gittens's ID, and called in police backup that ultimately led to the students' arrest and an overnight jail stay before all charges were dropped. The plaintiffs sued the university and its security officers under the equal-benefit clause of 42 U.S.C. Section 1981, and the trial court dismissed that claim for failure to allege state action, since the university was a private actor.