Doe v. Washoe County School District

CourtDistrict Court, D. Nevada
DecidedJanuary 22, 2024
Docket3:23-cv-00129
StatusUnknown

This text of Doe v. Washoe County School District (Doe v. Washoe County School District) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Doe v. Washoe County School District, (D. Nev. 2024).

Opinion

2 UNITED STATES DISTRICT COURT 3 DISTRICT OF NEVADA 4 JANE DOE, as Guardian of J. DOE, a Case No. 3:23-cv-00129-ART-CLB 5 minor, and in her individual capacity, ORDER) 6 Plaintiff, v. 7 WASHOE COUNTY SCHOOL 8 DISTRICT, et al.,

9 Defendants.

10 11 Plaintiff brings this case under 42 U.S.C. § 1983 on behalf of herself (Jane 12 Doe) and her minor child (J. Doe) alleging that Defendant Washoe County School 13 District (WCSD) has violated her and her child’s constitutional rights. Plaintiff 14 claims that WCSD, by issuing Administrative Regulation 5161, which establishes 15 district protocols related to transgender and gender non-conforming students, 16 has violated her Substantive Due Process parental rights, her child’s First 17 Amendment right to free speech, and their shared First Amendment right to the 18 free exercise of their religion. 19 In its Motion to Dismiss (ECF No. 24), WCSD argues, among other things, 20 that this Court lacks subject matter jurisdiction to hear Plaintiff’s claims. The 21 Court agrees and dismisses this action under Rule 12(b)(1) for lack of subject 22 matter jurisdiction and denies as moot Plaintiff’s Motion for Preliminary 23 Injunction (ECF No. 12). 24 I. BACKGROUND 25 J. Doe is a student at Depoali Middle School, which is in the WCSD. (ECF 26 No. 1 at 14, ¶ 1.) In January of 2023, J. Doe informed his mother that his teacher 27 had hung “a lesbian flag” in his classroom. (Id. at ¶ 2.) Plaintiff complained of the 28 flag to the school’s administration and was told by Depoali’s principal that 1 “hanging the flag was prohibited” under WCSD policy. (Id. at ¶ 3.) During that 2 conversation, she learned of WCSD’s Administrative Regulation 5161 and their 3 “Brave Space” program. 4 AR 5161 establishes guidelines around the treatment of transgender and 5 gender non-conforming students in the WCSD. Among other things, it prohibits 6 teachers from disclosing the gender identity of gender non-conforming students 7 to their parents and indicates that WCSD may consider it harassment for one 8 student to intentionally and persistently refuse to respect the gender identity of 9 another student. (Id. at 8, ¶ 7; 11, ¶ 27.) 10 The Brave Space program is an opt-in program for teachers, which allows 11 them to take a three-part course on making their classrooms supportive to 12 LGBTQ+ students. (Id. at 14-15, ¶ 8.) Teachers who complete the program receive 13 Brave Space placards, which they can display in their classrooms, indicating to 14 students that they “are [] safe staff member[s] to discuss matters pertaining to 15 sensitive topics.” (Id.) Although Plaintiff does not challenge the Brave Space 16 program in her Complaint, she argues without support in her Response that it is 17 related to AR 5161. 18 The Complaint alleges that, sometime after his mother spoke to the school 19 principal, J. Doe was “retaliated against” by WCSD. (Id. at 15, ¶¶ 9-11.) The 20 Complaint does not state the cause of that retaliation or assert a cause of action 21 for retaliation. Nor does the Complaint allege whether or how the retaliation was 22 related to AR 5161. 23 Plaintiff asserts eight causes of action. First, she asserts a violation of her 24 parental rights, under the Fourteenth Amendment, to direct the education of her 25 child, to direct the upbringing of her child, to direct the mental health and 26 medical decisions of her child, and to enjoy familial privacy (claims 1, 2, 3, and 27 7). Next, she asserts a violation of her child’s First Amendment rights to be free 28 from compelled speech and to enjoy the free exercise of his religion (claims 4 and 1 8). Finally, she argues that AR 5161 is invalid under the First and Fourteenth 2 Amendments because it is overbroad and vague (claims 5 and 6). 3 II. LEGAL STANDARD 4 A defendant may seek dismissal of a claim for lack of subject matter 5 jurisdiction. Fed. R. Civ. P. 12(b)(1). The party asserting claims in federal court 6 bears the burden of demonstrating the court’s jurisdiction over those claims. See 7 In re Dynamic Random Access Memory (DRAM) Antitrust Litig., 546 F.3d 981, 984 8 (9th Cir. 2008). 12(b)(1) attacks on subject matter jurisdiction can be facial or 9 factual. “Where a defendant claims only that the allegations contained in a 10 complaint are insufficient on their face to invoke federal jurisdiction,” the Court 11 treats their challenge as facial. Terenkian v. Republic of Iraq, 694 F.3d 1122, 1131 12 (9th Cir. 2012) (internal quotation marks and citations omitted). Defendants in 13 this case argue only that Plaintiff has failed to allege facts sufficient to establish 14 subject matter jurisdiction. The Court therefore treats Defendants’ jurisdictional 15 challenge as facial and asks “whether the complaint alleges sufficient factual 16 matter, accepted as true, to state a claim to relief that is plausible on its face.” 17 Terenkian, 694 F.3d at 1131 (internal quotation marks and citations omitted). 18 III. DISCUSSION 19 Defendants argue that Plaintiff fails to allege that she or her child have 20 suffered the kind of particularized injury necessary to establish standing to 21 challenge the constitutionality of AR 5161. Defendants argue that Plaintiff does 22 not allege facts in her Complaint that bring her and her son within the purview 23 of AR 5161, for example, by alleging that J. Doe was disciplined for violating AR 24 5161 or is otherwise subject to its provisions. Although Plaintiff responds that 25 her child was harmed by seeing the “lesbian flag” in his classroom and by the 26 school’s policy adopting the “Brave Space” “curriculum and protocol” by separate 27 regulation (ECF No. 36 at 9-10), her allegations related to “curriculum and 28 protocol” were not raised in her Complaint, and she does not explain how the 1 lesbian flag or Brave Space sticker are connected to AR 5161. 2 Article III of the United States Constitution requires that plaintiffs 3 demonstrate their standing to bring a case in federal court. Lujan v. Defenders of 4 Wildlife, 504 U.S. 555, 560 (1992). Without standing, the court has no 5 jurisdiction to hear the case, and the claims must be dismissed. To demonstrate 6 standing, a plaintiff must show (1) she suffered an “injury in fact,” (2) there is a 7 “causal connection between the injury and the conduct complained of,” (3) it is 8 “likely, as opposed to merely speculative, that the injury will be redressed by a 9 favorable decision.” Id. at 560-61. “The party invoking federal jurisdiction bears 10 the burden of establishing these elements.” Id. at 561. 11 Plaintiff alleges four sets of injuries: (1) her child witnessed a lesbian flag 12 and Brave Space sticker in one of his classrooms, “which he found offensive” (ECF 13 No. 1 at 14, ¶ 3; No. 36 at 9); (2) her child was subject to “‘Brave Space’ 14 curriculum and protocol under the Regulation of 516[1]” (ECF No. 36 at 9); (3) 15 her child was retaliated against by his school’s administration (ECF No. 1 at 15, 16 ¶ 9); (4) her parental rights and her and her child’s First Amendment rights could 17 be violated, were J. Doe’s behavior ever to fall under the purview of AR 5161. (See, 18 e.g., ECF No. 1 at 35, ¶ 113 (“Defendants’ actions . . . conflict with Plaintiffs’ 19 religious beliefs by prohibiting them from being informed of mental health issues 20 their children are or might be undergoing . . . .”).).

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Related

Lujan v. Defenders of Wildlife
504 U.S. 555 (Supreme Court, 1992)
Manuel Terenkian v. The Republic of Iraq
694 F.3d 1122 (Ninth Circuit, 2012)
In Re Dynamic Random Access Memory (Dram)
546 F.3d 981 (Ninth Circuit, 2008)

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Bluebook (online)
Doe v. Washoe County School District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/doe-v-washoe-county-school-district-nvd-2024.