Steve Frye’s golf lawsuits are a two-decade run of gender discrimination cases filed against California golf courses, pro shops, and instructors that offered women-only clinics or ladies’ discounts. Frye, an Orange County men’s rights activist, brings the suits under California’s Unruh Civil Rights Act, typically seeking the statute’s $4,000 minimum per alleged instance of discrimination. The results are mixed: some courses have quietly settled or dropped their women-only programs, several suits have been voluntarily dismissed, one was thrown out at the trial level, and one produced a published 2025 appellate ruling letting a case proceed to trial.
Who Steve Frye Is and How the Lawsuits Work
Frye is based in Orange County and has been identified as a former member of the National Coalition for Men, a San Diego nonprofit that has challenged gender-specific business practices through litigation.1The Coast News. Encinitas Golf Instructor Fights Lawsuit Over Women-Only Clinic San Diego attorney Alfred Rava, a board member of that organization, has represented him in most of the cases and says he has been involved in roughly 300 Unruh Act sex discrimination cases across Southern California.2NBC San Diego. Gender Discrimination: Men Are Suing Women for Not Letting Them Into Women-Only Events Frye often files with a co-plaintiff, most frequently fellow activist George St. George on the golf cases.3Palo Alto Online. Men’s Rights Activists Target Palo Alto Golf Course
Frye has framed the campaign as principled enforcement. On golf-course pricing, he has said: “Providing discounted green fees to only female patrons is as offensive, archaic and unlawful as giving discounted green fees to only male patrons, or charging people of color more than Caucasians for green fees.”4Los Angeles Times. Trump and Men’s Rights
The mechanic that makes the cases viable is the Unruh Civil Rights Act itself. It guarantees “full and equal accommodations, advantages, facilities, privileges, or services in all business establishments of every kind whatsoever,” with sex among the explicitly protected characteristics.5California Department of Civil Rights. Unruh Civil Rights Act Under the 1985 Koire v. Metro Car Wash decision, arbitrary sex discrimination by a business is injurious on its face, so a plaintiff does not have to prove actual damages. Statutory damages start at $4,000 per violation, plus attorney’s fees.6University of Chicago Legal Forum. Antidiscrimination Statutes and Women-Only Spaces in the MeToo Era Frye’s complaints routinely seek that $4,000 figure per plaintiff, per instance.
Reporting has variously described his total filings as “dozens, if not hundreds,” with at least 36 civil rights cases in San Diego County alone.1The Coast News. Encinitas Golf Instructor Fights Lawsuit Over Women-Only Clinic NBC 7 San Diego counted 26 as of 2017.2NBC San Diego. Gender Discrimination: Men Are Suing Women for Not Letting Them Into Women-Only Events The Los Angeles Times reported he had “sued dozens of California businesses over the years,” with roughly half settling.4Los Angeles Times. Trump and Men’s Rights Golf courses are one of his most frequent targets, alongside bars, restaurants, and sporting-goods stores.
Trump National Golf Club, Rancho Palos Verdes
Frye’s earliest widely reported golf case was a 2010 class action in Los Angeles County Superior Court against the Trump National Golf Club in Rancho Palos Verdes, over a 25% discount offered to women during breast cancer awareness month. A judge dismissed the case before trial, ruling that the promotion did not “perpetuate any kind of stereotype, but rather supported public awareness of breast cancer.” Frye appealed. Both the California Court of Appeal and the California Supreme Court declined to revive the case.4Los Angeles Times. Trump and Men’s Rights
Paso Robles Golf Club
In October 2019, Frye filed suit in San Luis Obispo Superior Court against the Paso Robles Golf Club, alleging he was intentionally denied equal access to drinks, range balls, equipment, instruction, and carts that were provided free to women during a “Ladies Educational/Social Golf Clinic” in October 2017.7San Luis Obispo Tribune. Men’s Rights Advocate Files Lawsuit Against Paso Robles Golf Club
Golf and Tennis Pro Shop
Frye, St. George, and a third co-plaintiff, Andrew Layus, sued Golf & Tennis Pro Shop, Inc. over women-only promotions at its California stores. The case is best known for a procedural appellate ruling on discovery. In Golf & Tennis Pro Shop, Inc. v. Superior Court (84 Cal.App.5th 127), the Court of Appeal held that the 45-day deadline to file a motion to compel interrogatory responses does not begin to run on unverified responses, and it upheld $4,447 in sanctions against the retailer for its procedural failures.8FindLaw. Golf & Tennis Pro Shop, Inc. v. Superior Court The ruling is now a discovery-practice citation well beyond its Unruh Act origins.
Frye v. Fore the Ladies
The most legally significant golf case is Frye v. Fore the Ladies. Frye and co-plaintiff Alex Maystrenko sued Fore the Ladies, Inc. (FTL), a nonprofit that hosts introductory golf clinics, and its founder Abby Liebenthal, alleging they were excluded from a women-only clinic at Goat Hill Park in Oceanside on June 13, 2021, in violation of the Unruh Act.9Midpage. Frye v. Fore the Ladies, D083759
The defendants tried to end the case with an anti-SLAPP motion, arguing their clinic activities were protected speech. The trial court denied it. On January 31, 2025, the California Court of Appeal affirmed, holding that the lawsuit targeted the “act of exclusion based on sex” rather than any protected speech or advocacy. Advertising and emails about the clinic may have communicated the alleged discrimination but did not form the basis for liability, and because the defendants failed to show the claims arose from protected activity, the court did not need to reach the merits.9Midpage. Frye v. Fore the Ladies, D083759 The underlying discrimination case can now proceed to trial. Fore the Ladies has since posted a nondiscrimination policy stating it “does not discriminate on the basis of race, color, religion (creed), gender, gender expression, age, national origin (ancestry), disability, marital status, sexual orientation, socioeconomic background, or military status.”10Fore the Ladies. What Happens at a FTL Golf Clinic
Encinitas Ranch Golf Course
Frye and St. George sued PGA instructor Heidi Richardson in 2024, alleging she denied them entry to women-only golf clinics at Encinitas Ranch Golf Course in violation of the Unruh Act. The plaintiffs voluntarily dismissed the case with prejudice on May 23, 2024, during an initial hearing. Rava said the dismissal came because the course had ended the sex-based clinics and the plaintiffs had “achieved their continuous goal of supporting California’s strong public policy to eradicate sex discrimination.” Richardson called it a victory and said she was “even more inspired and committed to being an advocate for women’s golf.”11The Coast News. Encinitas Golf Instructor Defeats Lawsuit by Men’s Rights Activists
Baylands Golf Links, Palo Alto
In April 2024, Frye and St. George sued the City of Palo Alto over a “Ladies Golf Clinic” at the municipal Baylands Golf Links, alleging they were denied entry after inquiring in late 2023. They sought $4,000 per instance. By late June 2024, their attorney asked the court to dismiss the suit with prejudice, meaning it cannot be refiled. No public reason was given.12Palo Alto Online. Men’s Rights Activists Drop Suit Against Palo Alto Golf Course
What the Golf Record Adds Up To
The scoreboard on Frye’s golf cases is uneven. Trump National was dismissed at the trial level and lost on appeal. Encinitas and Palo Alto were voluntarily dismissed with prejudice by the plaintiffs, with each side claiming the outcome as a victory. Golf & Tennis Pro Shop produced a plaintiff-favorable appellate ruling on discovery sanctions. Fore the Ladies is now cleared to proceed to trial after surviving an anti-SLAPP challenge. Paso Robles remains on the docket in the reporting available.
Rava characterizes the overall pattern as a perfect record, saying defendants “changed their tune” once sued.13Times of San Diego. San Diego Lawyer Suing No-Boys-Allowed Comic Claims 100 Win Record Defendants and critics describe the approach differently. Richardson, the Encinitas instructor, called Frye’s litigation a “career” spanning 20 years and argued the statutory $4,000 minimum creates a financial incentive to target small businesses and instructors who cannot afford to fight.1The Coast News. Encinitas Golf Instructor Fights Lawsuit Over Women-Only Clinic Based on available records, no California court has formally declared Frye a vexatious litigant or imposed filing restrictions on him.
Where Women-Only Golf Events Stand Under the Unruh Act
The Unruh Act’s reach is broad. The California Supreme Court has interpreted “business establishments” as widely as reasonably possible, which covers essentially any golf course, pro shop, or instructor open to the public. Gender-based pricing differences and exclusions from business events generally count as violations, and plaintiffs do not need to prove they suffered actual harm.
The California Department of Civil Rights has advised that businesses may host events that “spotlight” a particular group, but they should make clear that all are welcome to attend; public events that exclude people based on a protected characteristic generally violate the Act.5California Department of Civil Rights. Unruh Civil Rights Act Legal scholarship has noted that since the #MeToo era, most Unruh challenges to women-only spaces have settled rather than producing merits rulings.6University of Chicago Legal Forum. Antidiscrimination Statutes and Women-Only Spaces in the MeToo Era The Trump National dismissal shows that a charitable, awareness-based framing can survive scrutiny, but the Fore the Ladies ruling is a caution the other way: nonprofit status and educational purpose did not shield a women-only clinic from having to answer the discrimination claim on the merits. For any California golf course, pro shop, or instructor considering a women-only clinic or a ladies’ green-fee discount, that is the current legal terrain Frye’s cases have helped shape.