Brown v. Sweetwater Union High School District

District Court, S.D. California·Decided February 18, 2025·No. 3:24-cv-00493·Unknown

Opinion

LATEEFAH BROWN, Case No.: 24-CV-0493 W (MMP)

Plaintiff, ORDER DENYING DEFENDANTS’ v. MOTION TO DISMISS [DOC. 32] SCHOOL DISTRICT, et al., Defendants. Pending before the Court is Defendants’ motion to dismiss the First Amended Complaint (“FAC”) under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). The FAC asserts federal and state causes of action based on allegations of racial discrimination, harassment, and intimidation directed at Plaintiff while teaching at Sweetwater Union High School. Although Plaintiff does not allege that any of the individually named defendants posted or wrote any of the offensive messages or cartoons, she contends they are liable for their complete “indifference and inaction” to the conduct, which caused her to suffer fear, anxiety and severe emotional distress. The Court decides the matters on the papers submitted and without oral argument. See Civ. L.R. 7.1(d)(1). For the reasons stated below, the Court DENIES the motion to dismiss [Doc. 32]. A. The parties. From 2019 through December 2023, Plaintiff Lateefah Brown was a science teacher at Otay Ranch High School in Defendant Sweetwater Union High School District (the “District”). (FAC [Doc. 17] ¶ 4.) She was the only African American teacher in the science department and the only African American teacher instructing non-special education students at the school. (Id. ¶¶ 3, 5.) Beginning in August of 2020 and continuing until October 31, 2023, Plaintiff contends there were eight separate incidents of racial discrimination, harassment and intimidation directed at her. Defendant District employs over 3,000 teachers and staff. (FAC ¶ 7.) Defendant Dr. Moises Aguirre was the Superintendent during seven of the eight incidents of discrimination, harassment or intimidation described in the FAC. (Id. ¶ 8.) Defendant Mary Rose Peralta was the principal at Otay Ranch High School during three of the incidents. (Id. ¶ 14.) The remaining Defendants—Nicholas Segura, Adrian Arancibia, Marti Emerald, Elva Lopez-Zepeda and Arturo Solis (collectively, the “Trustee Defendants”)—were members of the District’s Board of Trustees during all or “many” of the incidents. (Id. ¶¶ 9–13.) B. Eight incidents of discrimination, harassment and intimidation. On Friday, August 28, 2020, Plaintiff received a message on her first period class Teams account stating: “Lateefah Brown u a bitch ass [N-word].” (FAC ¶ 60, n. 2.1) The message, which was visible to everyone in Plaintiff’s first period class, was posted after school and thus was not seen until the following Monday. (Id.) Plaintiff reported the incident to the then principal and assistant principal. (Id. ¶ 63.) The FAC alleges that Defendants did not condemn the conduct or take any meaningful action to investigate the incident or prevent future incidents. (Id. ¶¶ 64, 66–68.) The second incident occurred on Monday, September 28, 2020, when Plaintiff received the following communication on another online learning platform teachers used during remote learning: “Pussy,” “Foot,” “[N-word].” (FAC ¶¶ 69, 70, n. 3.) Plaintiff again immediately reported the incident to the then principal and vice principal. (Id. ¶ 71.) They never notified Plaintiff of any findings or measures to investigate the incident or prevent its recurrence. (Id. ¶ 72.) The FAC further alleges Defendants again did not condemn the behavior, did not tell other staff, students or the broader community about the incident, “did not take meaningful action to investigate this incident” and “did not take meaningful action after this incident to dissuade further acts of hate against Ms. Brown.” (Id. ¶¶ 74–77.) The third incident occurred on Thursday, October 1, 2020. (FAC ¶ 78.) During online learning, messages were sent in the classroom chat that were visible to all students. (Id.) The messages included racist and sexually explicit cartoons. (Id. ¶¶ 79–81.) Plaintiff again reported the incident to the principal and vice principal.2 (Id. ¶ 83.) In addition, Plaintiff emailed Dr. Joe Fulcher, the District Assistant Superintendent about the August, September and October incidents. (Id. ¶¶ 87, 88.) Plaintiff stated that she had “not been informed of adequate progress from the first or second incidents and the attacks/assaults have escalated since the first incident.” (Id. ¶ 89.) She also asserted that it was “the responsibility and obligation of the district to safeguard the students, employees and teaching staff from this explicit content” and requested a “swift, serious, high level response.” (Id. ¶ 90.) On October 7, Dr. Fulcher responded with an email stating that he was “monitoring [her] situation” and inviting her to participate in a “Black Minds Matter” advocacy group so she could “share [her] story with the group (for ideas about school and community interventions).” (Id. ¶ 93.) Plaintiff also emailed David Delacalzada, the District’s Director of Information Technology and Enterprise Architecture, seeking assistance to stop the online harassment. (FAC ¶ 94.) More than a month after emailing him, Mr. Delcalzada’s secretary emailed Plaintiff to schedule a remote meeting. (Id. ¶ 98.3) In addition to Plaintiff’s actions, on October 2, 2020, her fellow teachers in the Science Department pleaded with the principal and others in the administration to “do something to meaningfully support Ms. Brown and put an end to the repeated attacks.” (FAC ¶ 99.) Her peers recommended several potential steps that could be taken. (Id. ¶¶ 106–111.) However, the FAC alleges Defendants failed to condemn the behavior, did not tell staff or students about the behavior, and did not take any meaningful action to investigate or condemn the behavior. (Id. ¶¶ 112–116.) The fourth incident occurred on March 4, 2022, when Plaintiff found a school board eraser she had purchased with the N-word written on it. (FAC ¶ 117.) She reported the incident to Principal Peralta and the assistant principal. (Id. ¶ 119.) Defendants failed to condemn the behavior or take any meaningful action after the incident to investigate or dissuade further discrimination against Plaintiff. (Id. ¶¶ 120–124.) The next incident occurred on February 24, 2023, when Plaintiff discovered the N- word carved into a desk in her classroom. (FAC ¶ 125.) She immediately reported the incident to Principal Peralta and the assistant principal. (Id. ¶ 127.) She asked them and others if the District had a “policy on the use of hate speech or derogatory terms toward marginalized groups of people?” and stated that it was time to develop one and make “students, parents and teachers aware of it.” (Id. ¶¶ 128, 129.) In addition, Plaintiff’s colleagues again came to her defense and “implored Defendants to take swift action.” (Id. ¶ 133.) Nevertheless, Plaintiff contends Defendants again failed to condemn the behavior or take any meaningful action after the incident to investigate or dissuade further discrimination against Plaintiff. (Id. ¶¶ 135–137.) On April 27, 2023, Plaintiff “discovered a caricature of a monkey with a message bubble saying ‘hey monkey’ on the white board at the front of her Otay Ranch High School classroom.” (FAC ¶ 138.) She immediately reported it to Principal Peralta and the assistant principal. (Id. ¶ 140.) As a result of the repeated racist incidents directed at Plaintiff and the administration’s failure to take any action, Plaintiff contends she felt unsafe on campus and began suffering severe emotional distress. (Id. ¶¶ 141–143.) Plaintiff stopped teaching for the rest of the school year. (Id. ¶ 144.) When Plaintiff returned the following school year, she was hit by a water bottle while attending a school assembly on October 31, 2023. (FAC ¶ 164.) Another teacher soaked by the water from the bottle that hit Plaintiff took pictures of the students in the crowd. (Id. ¶ 165.) Although the assistant principal stated she would investigate th

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

Brown v. Sweetwater Union High School District, (S.D. Cal. 2025).

Brown v. Sweetwater Union High School District (Brown v. Sweetwater Union High School District) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Tenney v. Brandhove
341 U.S. 367 (Supreme Court, 1951)
Smith v. Wade
461 U.S. 30 (Supreme Court, 1983)
Papasan v. Allain
478 U.S. 265 (Supreme Court, 1986)
Rodriguez v. MARICOPA CTY. COMMUNITY COLLEGE DIST.
605 F.3d 703 (Ninth Circuit, 2010)
Vasquez v. Los Angeles County
487 F.3d 1246 (Ninth Circuit, 2007)
Alaska v. EEOC
564 F.3d 1062 (Ninth Circuit, 2009)
Pribula v. Wyoming Area School District
599 F. Supp. 2d 564 (M.D. Pennsylvania, 2009)
Bingham v. Oregon School Activities Ass'n
24 F. Supp. 2d 1110 (D. Oregon, 1998)
Zielonka v. Topinka
28 F. Supp. 2d 1081 (N.D. Illinois, 1998)
Morgan v. Yamada
26 Haw. 17 (Hawaii Supreme Court, 1921)
Sprewell v. Golden State Warriors
266 F.3d 979 (Ninth Circuit, 2001)
Bechard v. Rappold
287 F.3d 827 (Ninth Circuit, 2002)
Williams v. Alhambra School District No. 68
234 F. Supp. 3d 971 (D. Arizona, 2017)
Alvares v. Erickson
514 F.2d 156 (Ninth Circuit, 1975)