Brignac v. Clark County School District

District Court, D. Nevada·Decided May 30, 2025·No. 2:25-cv-00215·Unknown

Opinion

* * *

JARON BRIGNAC, Case No. 2:25-cv-00215- EJY

Plaintiff, ORDER v.

CLARK COUNTY SCHOOL DISTRICT; MANION MIDDLE SCHOOL; TODD PETERSON; TINA MILLER; CONNIE MCGRANDY; ZACH STARK, Defendants. Pending before the Court is Plaintiff’s Motion for Leave to File a Second Amended Complaint (ECF No. 19). The Court has considered the Motion along with Defendant’s Response (ECF No. 25). No reply was filed. The Court finds as follows. I. Procedural History Plaintiff Jaron Brignac initiated this action against Defendants on January 31, 2025 alleging violations of Title VII of the 1964 Civil Rights Act based on Defendants’ alleged failure to address persistent, racially motivated bullying his daughter supposedly suffered as a student at Mannion Middle School (“MMS”). ECF No. 1. Less than one week later, Plaintiff filed his First Amended Complaint (“FAC”) alleging that in the time since serving his original Complaint, his daughter had been expelled from MMS in what Plaintiff contends was an act of retaliation. ECF No. 7. Based on these allegations, Plaintiff omitted his Title VII claim and instead asserted a First Amendment retaliation claim (hereafter the “Retaliation” claim). Id. at 4-5. Plaintiff’s FAC also asserted violations of the Fourteenth Amendment’s Equal Protection Clause alleging (1) Defendants failed to properly investigate the bullying incidents or follow their internal policies regarding expulsion, (2) Plaintiff and his daughter suffered different (less favorable treatment) because of their race, and (3) similar incidents involving non-black parents and non-black students had not resulted in expulsion. Id. at 6. On February 27, 2025, Defendants filed a Motion to Dismiss Plaintiff’s FAC. ECF No. 15. In their Motion, Defendants seem to have mistaken Plaintiff to be asserting a claim under the Fourteenth Amendment’s Due Process Clause, rather than the Equal Protection Clause, as Defendants argue at various points that Plaintiff failed to establish a violation of the Due Process Clause. See, e.g., id. at 6 (“[T]here are no allegations as to how the Defendants violated Plaintiff’s Fourteenth Amended [sic] right to due process.”); id. at 12 (“[A] State’s failure to protect an individual against private violence simply does not constitute a violation of the Due Process Clause.”); id. at 16 (“[F]ail[ure] to follow the School District’s policies and procedures … is not a violation of the constitutional right to due process.”). Plaintiff responded by filing the instant Motion for Leave to Amend (“Plaintiff’s Motion”) to which he attached his proposed Second Amended Complaint (“SAC”). ECF No. 19. Likely intending to address the supposed deficiencies in what Defendants misconstrued as a Due Process claim, Plaintiff’s proposed SAC includes extensive new factual allegations asserting violations of the Due Process Clause of the Fifth Amendment. Id. at 9-12. The SAC also reasserts Plaintiff’s Retaliation and Equal Protection claims. Id. at 15-16. Plaintiff also filed an Opposition to Defendants’ Motion to Dismiss the FAC arguing the Motion was moot given the filing of the proposed SAC and the Court should therefore construe Defendants’ Motion as seeking dismissal of the proposed SAC. ECF No. 24 at 6. Defendants disagree maintaining their Motion to Dismiss is directed only at the FAC, ECF No. 26 at 3, while separately opposing Plaintiff’s Motion for Leave to Amend by arguing that the proposed amendments are futile, ECF No. 25. II. Discussion Under Rule 15 of the Federal Rules of Civil Procedure (“FRCP”), a party may amend its pleading once as a matter of course, but further amendments may only be made “with the opposing party’s written consent or the court’s leave.” Fed. R. Civ. Pro. 15(a)(2). The Court should nevertheless freely grant leave “when justice so requires.” Id. Despite this lenient standard, a district court “need not grant leave to amend where the amendment: (1) prejudices the opposing party; (2) is sought in bad faith; (3) produces an undue delay in litigation; or (4) is futile.” AmerisourceBergen Corp. v. Dialysist W., Inc., 465 F.3d 946, 951 (9th Cir. 2006); Foman v. Davis, 371 U.S. 178, 182 (1962). Here, Defendants oppose Plaintiff’s Motion solely on the basis of futility. ECF No. 25 at 1. Although courts generally “will defer consideration of challenges to the merits of a proposed amended pleading until after leave to amend is granted and the amended pleading is filed,” Netbula, LLC v. Distinct Corp., 212 F.R.D. 534, 539 (N.D. Cal. 2003), leave to amend is properly denied as futile when “no set of facts can be proved under the amendment to the pleadings that would constitute a valid and sufficient claim or defense.” Missouri ex rel. Koster v. Harris, 847 F.3d 646, 656 (9th Cir. 2017). That being said, it is the opposing party’s burden to show why leave to amend should not be granted. Louis v. Cnty. of Ventura, Case No. 2:22-cv-00493-FWS-KS, 2023 WL 6890766, at *1 (C.D. Cal. July 26, 2023) (citing DCD Programs, Ltd. v. Leighton, 833 F.2d 183, 185 (9th Cir. 1987)). Importantly, in their Opposition to Plaintiff’s Motion Defendants challenge only the portions of the proposed SAC that seek to assert additional claims. ECF No. 25. That is, no opposition—no effort to seek dismissal—is argued with respect to the Equal Protection or Retaliation claims. See id. Therefore, the Court limits its futility analysis to Defendants’ arguments addressing Due Process and civil conspiracy. “[P]roposed amendments are futile when they are either duplicative of existing claims or patently frivolous.” Murray v. Schriro, 745 F.3d 984, 1015 (9th Cir. 2014) (quoting Bonin v. Calderon, 59 F.3d 815, 846 (9th Cir. 1995)) (cleaned up). Applying this standard to Plaintiff’s proposed SAC, the Court finds the proposed changes largely fall into two categories. First, the SAC includes several pages worth of additional factual allegations broadly asserting that Plaintiff’s daughter was “deprived of life, liberty, and property without due process of law,” which the Court construes as a procedural due process claim. ECF No. 19 at 10. Second, the SAC adds a third cause of action for civil conspiracy. Id. at 11-12. The Court considers these two proposed amendments in sequence. A. Procedural Due Process Claim. Plaintiff’s due process allegations in the proposed SAC all arise from Clark County School District’s (“CCSD”) internal policies regarding the expulsion of students. Plaintiff first alleges that these policies violate the Due Process Clause1 because they allow for the expulsion of a student for battery without the student having been convicted of criminal battery. Id. at 9-10. Plaintiff alleges this is what happened to his daughter, noting that she was expelled on February 4, 2025, while the court date for her battery charge was not until March 6, 2025. Id. at 9. Separately, Plaintiff alleges Defendants did not follow the procedures outlined in these policies when deciding to expel his daughter. Specifically, Plaintiff alleges that although CCSD policies require issuance of a notice of suspension, a hearing in which the principal discloses information obtained during the investigation of the underl

Free access — add to your briefcase to read the full text and ask questions with AI

Brignac v. Clark County School District, (D. Nev. 2025).

Brignac v. Clark County School District (Brignac v. Clark County School District) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Lilienthal's Tobacco v. United States
97 U.S. 237 (Supreme Court, 1878)
Foman v. Davis
371 U.S. 178 (Supreme Court, 1962)
Broadrick v. Oklahoma
413 U.S. 601 (Supreme Court, 1973)
Goss v. Lopez
419 U.S. 565 (Supreme Court, 1975)
Mark Wynar v. Douglas County School District
728 F.3d 1062 (Ninth Circuit, 2013)
Singer Ex Rel. Singer v. Wadman
595 F. Supp. 188 (D. Utah, 1982)
Robert Murray v. Dora Schriro
745 F.3d 984 (Ninth Circuit, 2014)
State of Missouri v. Kamala Harris
847 F.3d 646 (Ninth Circuit, 2016)
Johns v. County of San Diego
114 F.3d 874 (Ninth Circuit, 1997)
Turner v. Rogers
180 L. Ed. 2d 452 (Supreme Court, 2011)
Netbula, LLC v. Distinct Corp.
212 F.R.D. 534 (N.D. California, 2003)
K. J. v. Jackson
127 F.4th 1239 (Ninth Circuit, 2025)