Guilford v. Athena Career Academy

CourtDistrict Court, N.D. Ohio
DecidedNovember 4, 2020
Docket3:19-cv-02208
StatusUnknown

This text of Guilford v. Athena Career Academy (Guilford v. Athena Career Academy) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Guilford v. Athena Career Academy, (N.D. Ohio 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO WESTERN DIVISION

Kenasia Guilford, Case No. 3:19 CV 2208

Plaintiff, SUMMARY JUDGMENT ORDER

-vs- JUDGE JACK ZOUHARY

Athena Education Group, LTD, et al.,

Defendants.

INTRODUCTION No one likes being called to the principal’s office -- an anxious and uneasy feeling some remember from childhood. In February 2019, Plaintiff Kenasia Guilford, a nursing student, was asked to report to the office of her program director. Within minutes, Guilford would be dismissed from school. This suit followed. BACKGROUND Guilford was enrolled as a student in the “LPN to RN” program at Athena Career Academy (“Athena”) (Doc. 1 at ¶¶ 13–15). Defendant Suzanne Smith was the Program Director of Nursing Education at Athena (id. at ¶ 7). Guilford is black; Smith is white (Doc. 1 at ¶ 35). In February 2019, a male faculty member approached Smith about Guilford’s classroom behavior (Doc. 31 at 109–10). He indicated other students were complaining that Guilford was “disrupting the classroom” (id. at 111). Smith set a meeting with Guilford that same morning (id. at 109–10). Smith, who is hearing impaired, asserts Guilford just “glare[d]” and “smirk[ed]” upon arriving in her office, yet refused to talk (id. at 6, 120). According to Guilford, she is “naturally soft spoken” and was unaware Smith had a hearing impairment (Doc. 27 at 2). Guilford asserts that Smith “rudely” commented on her facial expressions, asking if she wanted to continue in the program (id.). Guilford replied: “[I] paid to be in the program” (id.). Smith then dismissed Guilford “for the day,” and began to escort her to retrieve her belongings (Doc. 31 at 123). On the way out of her office, Smith admonished Guilford: “you’re [going to] learn to be respectful” (id. at 3). When Smith asked

Guilford which classroom was hers, Guilford snapped: “[T]he front one, you’re the dean, you should know which class I attend” (Doc. 27 at 3). Smith then dismissed Guilford: “[T]hat’s it! You’re done with my program!” (id.). Smith claims Guilford swore at her and acted in a threatening manner by “invad[ing]” her personal space in the hallway (Doc. 31 at 124–25); Guilford denies these allegations (Doc. 20 at 158). After her dismissal, Guilford filed this suit, asserting: (1) a due-process violation; (2) an equal- protection violation, and (3) unjust enrichment (Doc. 1 at ¶¶ 29–46). Defendants move for Summary Judgment, which has been fully briefed (Docs. 20–22). Magistrate Judge James Knepp filed a Report and Recommendation (“R&R”), recommending this Court dismiss each of Guilford’s claims

(Doc. 32). Guilford now objects (Doc. 33); Defendants reply (Doc. 34). DISCUSSION Procedural Due Process With respect to Guilford’s due-process claim, Magistrate Judge Knepp determined that Athena was not a state actor: “[Guilford] does not argue, provide any proof, or cite to any case law to suggest Defendants may be held liable as state actors under any of the recognized tests -- she needed to do so to survive summary judgment” (Doc. 32 at 6) (citing Faparusi v. Case Western Reserve Univ., 711 F. App’x 269, 275–76 (6th Cir. 2017)). Guilford objects, arguing (Doc. 33 at 2): [T]he State of Ohio has delegated training authority it would otherwise retain to Defendants. Further, [Athena] teach[es] a curriculum provided by the [S]tate in an effort to obtain state licensure. [Athena] does not operate outside this capacity rendering its relationship with [the State] inextricable to its existence and operation, . . . [which] makes it a “state actor” within the meaning of § 1983.

A private party may become a state actor under the “nexus test” when there is a close relationship between the state and private actor, usually by way of a state regulation or contract. Wolotsky v. Huhn, 960 F.2d 1331, 1335 (6th Cir. 1992). Guilford’s argument without legal authority, that Athena is a state actor, fails for two reasons. First, the State of Ohio does not dictate Athena’s disciplinary policies, nor was it involved in the actions taken by Smith. In Blackburn v. Fisk University, plaintiffs argued their constitutional rights were violated when they were suspended. 443 F.2d. 121, 122 (6th Cir. 1971). The Sixth Circuit found the private university was not a state actor because the “matters of alleged State involvement [were] in no way concerned with the actions taken by the school officials” and because the State “[did] not dictate the disciplinary policies of the school.” Id. at 124. So too here. See Doe v. Case W. Reserve Univ., 2017 WL 3840418, at *8 (N.D. Ohio 2017) (“The ultimate issue in determining whether a person or entity is subject to suit under § 1983 is the same as state action required under the Fourteenth Amendment, that is -- is the alleged infringement of federal rights fairly attributable to the State?”) (citations and quotation marks omitted)). Second, the use of certain curriculum to achieve state licensure is not sufficient to transform Athena into a state actor. If this were true, every private institution that prepares students for state- mandated professional exams would be subject to liability under Section 1983. For instance, in Grafton v. Brooklyn Law School, the Second Circuit found the private law school was not a state actor -- even though the school had to follow state regulations in order to retain its accreditation so graduates could pursue state licensure. 478 F.2d 1137, 1142–43 (2d Cir. 1973). Similarly, following state regulations in order for its students to be eligible for a state-sanctioned nursing license is not a sufficient “nexus” to transform Athena into a state actor. Guilford’s due-process claim fails. Equal Protection Guilford next alleges that “Defendants violated [her] civil rights by treating her differently than other similarly situated students . . . who were not African American” (Doc. 1 at ¶ 35). As noted

in the R&R, Guilford is vague as to the basis of her claim. However, in summary judgment briefing, Defendants characterize Guilford’s claim as arising under 42 U.S.C. § 1981 (Doc. 20 at 12); a characterization Guilford does not dispute (Doc. 21 at 12–13). Under Section 1981, Guilford must prove that: “(1) she is a member of a protected class; (2) she suffered an adverse action at the hands of [D]efendants in her pursuit of her education; (3) she was qualified to continue in her pursuit of her education; and (4) she was treated differently from similarly situated students who are not members of the protected class.” Bell v. Ohio State Univ., 351 F.3d 240, 253 (6th Cir. 2003) (citation omitted). Only the fourth element is in dispute (Doc. 32 at 7). Guilford objects to the Magistrate Judge’s conclusion that she failed to prove this element

because she did not “(1) identify the race of [her] tablemate . . . or (2) show that [she] was disciplined for disrupting class, while the other (presumably [white]) offenders were not” (id. at 8). Guilford claims she did both of those things in her Opposition Brief, which reads (Doc. 21 at 11): Additionally, the student statements . . . named both [Guilford] and the student who shared her workspace as the culprits of the offending behavior but only [Guilford] was sent to [Smith]’s office. This [] decision to send [Guilford] and not her white counterpart is the genesis of her dismissal. It is the disparate treatment that [Guilford] referenced in her claim.

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

Related

Cite This Page — Counsel Stack

Bluebook (online)
Guilford v. Athena Career Academy, Counsel Stack Legal Research, https://law.counselstack.com/opinion/guilford-v-athena-career-academy-ohnd-2020.