Harden v. West Side Career and Technology Center

CourtDistrict Court, M.D. Pennsylvania
DecidedSeptember 15, 2025
Docket3:23-cv-01631
StatusUnknown

This text of Harden v. West Side Career and Technology Center (Harden v. West Side Career and Technology Center) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Harden v. West Side Career and Technology Center, (M.D. Pa. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA SA’RAYA HARDEN, : CIV. NO. 3:23-CV-01631 : Plaintiff, : : v. : (Magistrate Judge Schwab) : WEST SIDE CAREER AND : TECHNOLOGY CENTER, et al., : : Defendants. :

MEMORANDUM OPINION

I. Introduction. This case is rooted in the death of Adreya Harden (“Adreya”) at the age of 15. Adreya died by suicide on October 5, 2021. Shortly before her death, Adreya faced bullying at school because she was transgender. Adreya’s mother, Saraya Harden (“Harden”), now brings § 1983 claims against Adreya’s school, school district, and principal. All parties are in agreement that Adreya’s death is a tragedy. See doc. 39 at 10 (“The Tech Defendants first want to recognize the tragedy before the Court. The weight of student suicide is crippling to all parties and cannot be overlooked.”); see also doc. 40 at 9 (same). The parties do not agree, however, whether the defendants violated Adreya’s constitutional rights and thereby caused her suicide. Thus, currently pending is the defendants’ motion for summary judgment. For the reasons that follow, we will grant in part and deny in part the motion for summary judgment.

II. Background and Procedural History. Harden initiated this action by filing a complaint on October 2, 2023. Doc. 1.

Harden filed the complaint as Adreya’s mother and the administrator of Adreya’s estate. Doc. 1 ¶ 16. In the complaint, Harden named 13 defendants, including 10 Doe defendants which were later dismissed by the parties’ stipulation. See docs. 1, 34. The three remaining defendants are: (1) Wyoming Valley School District

(“School District”); (2) West Side Career and Technology Center (“Tech”); and (3) Richard Rava, the Principal of Tech (“Principal Rava”). Doc. 1. The complaint brings claims against the defendants under Title IX, 42

U.S.C. § 1983, and state law. Doc. 1. The defendants filed a partial motion to dismiss, which we granted in part and denied in part. Docs. 8, 25, 26. The parties also entered into stipulations regarding the dismissal of certain claims. Docs. 29, 34. Accordingly, when the motion for summary judgment was filed the following

claims remained: (1) § 1983 claims for failure to train against Tech (Count V), Principal Rava (Count V), and the School District (Count VI); and (2) § 1983 claims for sex-based discrimination in violation of the equal protection clause against Tech (Count VII), the School District (Count VIII), and Principal Rava (Count IX). See docs. 1, 26, 29, 34.

The parties consented to our jurisdiction pursuant to 28 U.S.C. § 636(c) on February 21, 2024. Doc. 18. Although we issued a case management order on March 27, 2024, the parties later jointly filed a motion to bifurcate discovery (doc.

28), which we granted (doc. 30). Accordingly, the parties conducted discovery limited only to the issue of liability, with fact discovery to close on or before October 30, 2024, and dispositive motions and briefs in support thereof due on or before December 2, 2024. Doc. 30.

The defendants filed a single motion for summary judgment. Doc. 35. Tech and Principal Rava jointly filed a brief in support thereof (doc. 39) and the School District filed its own brief in support (doc. 40). Tech and Principal Rava jointly

filed a statement of material facts, and the School District filed an identical statement of material facts. Docs. 39-1, 40-1. Harden filed a single brief in opposition (doc. 50) and a counterstatement of material facts (doc. 49). Tech and Principal Rava filed a reply brief. Doc. 51. The motion for summary judgment is

thus ripe for review. III. Summary Judgment Standards. The defendants move for summary judgment under Rule 56(a) of the Federal

Rules of Civil Procedure, which provides that “[t]he court shall grant summary judgment if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P.

56(a). “Through summary adjudication the court may dispose of those claims that do not present a ‘genuine dispute as to any material fact’ and for which a jury trial would be an empty and unnecessary formality.” Goudy-Bachman v. U.S. Dept. of Health & Human Services, 811 F. Supp. 2d 1086, 1091 (M.D. Pa. 2011) (quoting

Fed. R. Civ. P. 56(a)). The moving party bears the initial responsibility of informing the court of the basis for its motion and identifying those portions of the record that

demonstrate the absence of a genuine dispute of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). With respect to an issue on which the nonmoving party bears the burden of proof, the moving party may discharge that burden by “‘showing’—that is, point out to the district court—that there is an

absence of evidence to support the nonmoving party’s case.” Id. at 325. Once the moving party has met its burden, the nonmoving party may not rest upon the mere allegations or denials of its pleading; rather, the nonmoving party

must show a genuine dispute by “citing to particular parts of materials in the record, including depositions, documents, electronically stored information, affidavits or declarations, stipulations (including those made for purposes of the

motion only), admissions, interrogatory answers, or other materials” or “showing that the materials cited do not establish the absence . . . of a genuine dispute.” Fed. R. Civ. P. 56(c). If the nonmoving party “fails to make a showing sufficient to

establish the existence of an element essential to that party’s case, and on which that party will bear the burden at trial, summary judgment is appropriate.” Celotex, 477 U.S. at 322. Summary judgment is also appropriate if the nonmoving party provides

merely colorable, conclusory, or speculative evidence. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249 (1986). There must be more than a scintilla of evidence supporting the nonmoving party and more than metaphysical doubt as to the

material facts. Id. at 252. “Where the record taken as a whole could not lead a rational trier of fact to find for the non-moving party, there is no ‘genuine issue for trial.’” Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 586 (1986).

The substantive law identifies which facts are material, and “[o]nly disputes over facts that might affect the outcome of the suit under the governing law will properly preclude the entry of summary judgment.” Anderson, 477 U.S. at 248. A

dispute about a material fact is genuine only if there is a sufficient evidentiary basis that would allow a reasonable fact finder to return a verdict for the non- moving party. Id. at 248–49.

When “faced with a summary judgment motion, the court must view the facts ‘in the light most favorable to the nonmoving party.’” N.A.A.C.P. v. N. Hudson Reg’l Fire & Rescue, 665 F.3d 464, 475 (3d Cir. 2011) (quoting Scott v.

Harris,

Related

Washington v. Davis
426 U.S. 229 (Supreme Court, 1976)
Wayte v. United States
470 U.S. 598 (Supreme Court, 1985)
City of Cleburne v. Cleburne Living Center, Inc.
473 U.S. 432 (Supreme Court, 1985)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
City of Canton v. Harris
489 U.S. 378 (Supreme Court, 1989)
Scott v. Harris
550 U.S. 372 (Supreme Court, 2007)
Woloszyn v. County of Lawrence
396 F.3d 314 (Third Circuit, 2005)
Village of Willowbrook v. Olech
528 U.S. 562 (Supreme Court, 2000)
Goudy-Bachman v. United States Department of Health & Human Services
811 F. Supp. 2d 1086 (M.D. Pennsylvania, 2011)
Lawrence Thomas v. Cumberland County
749 F.3d 217 (Third Circuit, 2014)
Bryan Santini v. Joseph Fuentes
795 F.3d 410 (Third Circuit, 2015)
Syed Hassan v. City of New York
804 F.3d 277 (Third Circuit, 2015)

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