A.S. v. Board of Education for DesPlaines School District 62

CourtDistrict Court, N.D. Illinois
DecidedMarch 31, 2023
Docket1:22-cv-04745
StatusUnknown

This text of A.S. v. Board of Education for DesPlaines School District 62 (A.S. v. Board of Education for DesPlaines School District 62) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
A.S. v. Board of Education for DesPlaines School District 62, (N.D. Ill. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

A.S., as parent and next friend of F.S. a minor, ) ) Plaintiff, ) Case No. 22 C 4745 ) v. ) ) Judge Robert W. Gettleman BOARD OF EDUCTION FOR DESPLAINES ) SCHOOL DISTRICT #62, DR. PAUL HERTEL, ) and ANIA FIGUEROA, ) ) Defendants. )

MEMORANDUM OPINION AND ORDER

Plaintiff A.S. as parent and next friend of her son minor F.S., has brought a two-count amended complaint (“complaint”) against defendants Board of Education for Des Plaines School District #62, Dr. Paul Hertel and Ania Figueroa seeking to “redress acts of bullying and the sexual assault against F.S. by other students that occurred on school premises and a school bus.” Count I, brought pursuant to 42 U.S.C. § 1983, alleges a violation of F.S.’s right to bodily integrity in violation of the Fourth and Fourteenth Amendments to the U.S. Constitution. Count II alleges a violation of Title IX of the Education Amendments of 1972, 20 U.S.C § 1681 et seq. Defendants have moved to dismiss the complaint under Fed. R. Civ. P. 12(b)(6) for failure to state a claim. For the reasons explained below, the motion is granted in part and denied in part. BACKGROUND1 According to the complaint, during the relevant time period F.S. was a student at Forest School, which is within the Des Plaines School District # 62 (the “District”). Defendant Dr.

1 The background facts are taken from the complaint and are assumed true for purposes of resolving the instant motion. Adam v. Miller Brewing Co., 709 F.3d 662, 665-66 (7th Cir. 2013). Hertel was employed by the Board of Education (“Board”) for the district as the superintendent. Figueroa was employed as the principal of Forest School. The complaint alleges the F.S. was “bullied and sexually assaulted for the first time when he was in second grade. He did not tell anyone about this assault until February 25, 2020, when

he sent a note to his third-grade teacher, Ms. Sampson. Sampson and Figueroa emailed F.S’s parents, indicating that another student, Julian, sexually assaulted F.S. in school and that Figueroa would “take care of it.” Despite the email, Figueroa took no action. On March 4, 2020, F.S. was stabbed with a pencil by a student. The parents reported this incident to the Board and Dr. Hertel. One year later, Matt Peebles, the school’s fourth grade teacher, sent an email to F.S.’s parents indicating that several other students dragged F.S. into a corner of the playground and kicked, punched, and pulled his penis. The parents reported this incident to Dr. Hertel and the Board. After reporting these incidents, the parents learned from other staff members that other students beside Julian were physically and verbally abusing F.S. None of these students were ever disciplined.

At the parents’ request, F.S. transferred to Iroquois School for fifth grade. On May 10, 2022, Iroquois Principal Kelly Krueger informed the parents that F.S. had been the victim of continued verbal and physical attacks by other students, including a student grabbing F.S.’s crotch and penis. Some of these attacks occurred in school and some on the bus. Krueger reported these incidents to Dr. Hertel, but Hertel never reported the incidents to the Board. Other than moving Julian’s classroom seat assignment, defendants took no other action to protect F.S.

2 DISCUSSION Defendants have moved to dismiss both counts under Fed. R. Civ. P. 12(b)(6). Such a motion challenges the sufficiency of the complaint, not its merits. Fed. R. Civ. P. 12(b)(6); see

Gibson v. City of Chi., 910 F.2d 1510, 1520 (7th Cir. 1990). To survive a Rule 12(b)(6) motion, the complaint must not only provide the defendant with fair notice of a claim’s basis but must also be facially plausible. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009); see also Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678. Count I is brought under § 1983, which “provides a remedy for violations of federal rights committed by persons acting under color of state law.” First Midwest Bank v. City of Chi., 988 F.3d 978, 986 (7th Cir. 2021). To state a § 1983 claim, a plaintiff must allege a deprivation of a right secured by the Constitution or laws of the United States. Id. In the

instant case, plaintiff alleges defendants violated F.S.’s substantive due process right to bodily integrity under the Fourteenth Amendment. F.S. undoubtedly has a liberty interest in his own physical safety and bodily integrity. See Doe v. School District U-46, 557 F.Supp.3d 860, 871-72 (N.D. Ill. 12021). Plaintiff does not allege, however, that any of the defendants personally deprived F.S. of that interest. Instead, plaintiff alleges that F.S. was deprived of that interest because defendants failed to protect him from the bullying and sexual assaults of other students. But, as the Supreme Court has noted, “nothing in the language of the Due Process Clause itself requires the State to protect the life,

3 liberty, and property of its citizens against invasion by private actors.” DeShaney V. Winnebago County Dep’t of Soc. Servs., 489 U.S. 189, 195-96 (1989). The Clause is a limitation on the State’s power to act. “Its purpose was to protect the people from the State, not to ensure that the State protected them from each other.” Id. at 196. Thus, “the Due Process

Clauses generally confer no affirmative right to governmental aid, even where such aid may be necessary to secure life, liberty, or property interests of which the government itself may not deprive the individual.” Id. Deshaney recognized two limited exceptions to the general rule that the State is not required to protect people from each other. Under the first, often called the special or custodial relationship exception, the state has an affirmative duty to provide for the safety of a person it has taken into custody involuntarily. Id. at 199-200. The duty arises from the State’s affirmative act of restraining the individual’s freedom to act on his own behalf, which is the deprivation of liberty that triggers the Due Process Clause, not its failure to act to protect the individual’s liberty interests against harms inflicted by other means. Id. at 200.

Plaintiff argues that this exception applies because the State has passed an in loco parentis statute, creating a special relationship between defendants and F.S. The court disagrees. For the special relationship or custodial relationship to apply, “the individual must be involuntarily taken into custody by the state.” Stevens v. Umsted, 131 F.3d 697, 202 (7th Cir. 1997). In the instant case, the state never took custody of F.S.

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A.S. v. Board of Education for DesPlaines School District 62, Counsel Stack Legal Research, https://law.counselstack.com/opinion/as-v-board-of-education-for-desplaines-school-district-62-ilnd-2023.