Brown v. Sweetwater Union High School District

CourtDistrict Court, S.D. California
DecidedFebruary 18, 2025
Docket3:24-cv-00493
StatusUnknown

This text of Brown v. Sweetwater Union High School District (Brown v. Sweetwater Union High School District) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 LATEEFAH BROWN, Case No.: 24-CV-0493 W (MMP)

12 Plaintiff, ORDER DENYING DEFENDANTS’ 13 v. MOTION TO DISMISS [DOC. 32] 14 SWEETWATER UNION HIGH SCHOOL DISTRICT, et al., 15 Defendants. 16 17 18 Pending before the Court is Defendants’ motion to dismiss the First Amended 19 Complaint (“FAC”) under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). The 20 FAC asserts federal and state causes of action based on allegations of racial 21 discrimination, harassment, and intimidation directed at Plaintiff while teaching at 22 Sweetwater Union High School. Although Plaintiff does not allege that any of the 23 individually named defendants posted or wrote any of the offensive messages or 24 cartoons, she contends they are liable for their complete “indifference and inaction” to the 25 conduct, which caused her to suffer fear, anxiety and severe emotional distress. 26 The Court decides the matters on the papers submitted and without oral argument. 27 See Civ. L.R. 7.1(d)(1). For the reasons stated below, the Court DENIES the motion to 28 dismiss [Doc. 32]. 1 I. BACKGROUND 2 A. The parties. 3 From 2019 through December 2023, Plaintiff Lateefah Brown was a science 4 teacher at Otay Ranch High School in Defendant Sweetwater Union High School District 5 (the “District”). (FAC [Doc. 17] ¶ 4.) She was the only African American teacher in the 6 science department and the only African American teacher instructing non-special 7 education students at the school. (Id. ¶¶ 3, 5.) Beginning in August of 2020 and 8 continuing until October 31, 2023, Plaintiff contends there were eight separate incidents 9 of racial discrimination, harassment and intimidation directed at her. 10 Defendant District employs over 3,000 teachers and staff. (FAC ¶ 7.) Defendant 11 Dr. Moises Aguirre was the Superintendent during seven of the eight incidents of 12 discrimination, harassment or intimidation described in the FAC. (Id. ¶ 8.) Defendant 13 Mary Rose Peralta was the principal at Otay Ranch High School during three of the 14 incidents. (Id. ¶ 14.) The remaining Defendants—Nicholas Segura, Adrian Arancibia, 15 Marti Emerald, Elva Lopez-Zepeda and Arturo Solis (collectively, the “Trustee 16 Defendants”)—were members of the District’s Board of Trustees during all or “many” of 17 the incidents. (Id. ¶¶ 9–13.) 18 19 B. Eight incidents of discrimination, harassment and intimidation. 20 On Friday, August 28, 2020, Plaintiff received a message on her first period class 21 Teams account stating: “Lateefah Brown u a bitch ass [N-word].” (FAC ¶ 60, n. 2.1) The 22 message, which was visible to everyone in Plaintiff’s first period class, was posted after 23 school and thus was not seen until the following Monday. (Id.) Plaintiff reported the 24 incident to the then principal and assistant principal. (Id. ¶ 63.) The FAC alleges that 25 Defendants did not condemn the conduct or take any meaningful action to investigate the 26 incident or prevent future incidents. (Id. ¶¶ 64, 66–68.) 27 28 1 The second incident occurred on Monday, September 28, 2020, when Plaintiff 2 received the following communication on another online learning platform teachers used 3 during remote learning: “Pussy,” “Foot,” “[N-word].” (FAC ¶¶ 69, 70, n. 3.) Plaintiff 4 again immediately reported the incident to the then principal and vice principal. (Id. ¶ 5 71.) They never notified Plaintiff of any findings or measures to investigate the incident 6 or prevent its recurrence. (Id. ¶ 72.) The FAC further alleges Defendants again did not 7 condemn the behavior, did not tell other staff, students or the broader community about 8 the incident, “did not take meaningful action to investigate this incident” and “did not 9 take meaningful action after this incident to dissuade further acts of hate against Ms. 10 Brown.” (Id. ¶¶ 74–77.) 11 The third incident occurred on Thursday, October 1, 2020. (FAC ¶ 78.) During 12 online learning, messages were sent in the classroom chat that were visible to all students. 13 (Id.) The messages included racist and sexually explicit cartoons. (Id. ¶¶ 79–81.) Plaintiff 14 again reported the incident to the principal and vice principal.2 (Id. ¶ 83.) In addition, 15 Plaintiff emailed Dr. Joe Fulcher, the District Assistant Superintendent about the August, 16 September and October incidents. (Id. ¶¶ 87, 88.) Plaintiff stated that she had “not been 17 informed of adequate progress from the first or second incidents and the attacks/assaults 18 have escalated since the first incident.” (Id. ¶ 89.) She also asserted that it was “the 19 responsibility and obligation of the district to safeguard the students, employees and 20 teaching staff from this explicit content” and requested a “swift, serious, high level 21 response.” (Id. ¶ 90.) On October 7, Dr. Fulcher responded with an email stating that he 22 was “monitoring [her] situation” and inviting her to participate in a “Black Minds 23 Matter” advocacy group so she could “share [her] story with the group (for ideas about 24 school and community interventions).” (Id. ¶ 93.) 25 Plaintiff also emailed David Delacalzada, the District’s Director of Information 26 Technology and Enterprise Architecture, seeking assistance to stop the online 27 28 1 harassment. (FAC ¶ 94.) More than a month after emailing him, Mr. Delcalzada’s 2 secretary emailed Plaintiff to schedule a remote meeting. (Id. ¶ 98.3) 3 In addition to Plaintiff’s actions, on October 2, 2020, her fellow teachers in the 4 Science Department pleaded with the principal and others in the administration to “do 5 something to meaningfully support Ms. Brown and put an end to the repeated attacks.” 6 (FAC ¶ 99.) Her peers recommended several potential steps that could be taken. (Id. ¶¶ 7 106–111.) However, the FAC alleges Defendants failed to condemn the behavior, did not 8 tell staff or students about the behavior, and did not take any meaningful action to 9 investigate or condemn the behavior. (Id. ¶¶ 112–116.) 10 The fourth incident occurred on March 4, 2022, when Plaintiff found a school 11 board eraser she had purchased with the N-word written on it. (FAC ¶ 117.) She reported 12 the incident to Principal Peralta and the assistant principal. (Id. ¶ 119.) Defendants failed 13 to condemn the behavior or take any meaningful action after the incident to investigate or 14 dissuade further discrimination against Plaintiff. (Id. ¶¶ 120–124.) 15 The next incident occurred on February 24, 2023, when Plaintiff discovered the N- 16 word carved into a desk in her classroom. (FAC ¶ 125.) She immediately reported the 17 incident to Principal Peralta and the assistant principal. (Id. ¶ 127.) She asked them and 18 others if the District had a “policy on the use of hate speech or derogatory terms toward 19 marginalized groups of people?” and stated that it was time to develop one and make 20 “students, parents and teachers aware of it.” (Id. ¶¶ 128, 129.) In addition, Plaintiff’s 21 colleagues again came to her defense and “implored Defendants to take swift action.” (Id. 22 ¶ 133.) Nevertheless, Plaintiff contends Defendants again failed to condemn the behavior 23 or take any meaningful action after the incident to investigate or dissuade further 24 discrimination against Plaintiff. (Id. ¶¶ 135–137.) 25 On April 27, 2023, Plaintiff “discovered a caricature of a monkey with a message 26 bubble saying ‘hey monkey’ on the white board at the front of her Otay Ranch High 27 28 1 School classroom.” (FAC ¶ 138.) She immediately reported it to Principal Peralta and the 2 assistant principal. (Id. ¶ 140.) As a result of the repeated racist incidents directed at 3 Plaintiff and the administration’s failure to take any action, Plaintiff contends she felt 4 unsafe on campus and began suffering severe emotional distress. (Id.

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Brown v. Sweetwater Union High School District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-sweetwater-union-high-school-district-casd-2025.