Johnson v. Chandler Unified School District

CourtDistrict Court, D. Arizona
DecidedSeptember 9, 2024
Docket2:24-cv-00530
StatusUnknown

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

Bluebook
Johnson v. Chandler Unified School District, (D. Ariz. 2024).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA 8 9 Jeremy Johnson, et al., No. CV-24-00530-PHX-MTL 10 Plaintiffs, ORDER 11 v. 12 Chandler Unified School District, et al., 13 Defendants. 14 15 I. 16 Plaintiffs, a high school football player, KJ, and his parents allege that KJ was 17 harassed and assaulted by fellow players. They also contend that the school administration 18 and football staff knew but failed to prevent it from continuing. 19 The Court now considers the Motion to Dismiss the Amended Complaint filed by 20 Defendants Chandler Unified School District, Michael Franklin, James Culver, Luke 21 Hickey, Richard Garretson, Brett Boyd, and Frank Narducci (collectively, the “CUSD 22 Defendants”). (Doc. 34) The Motion is fully briefed. The CUSD Defendants request oral 23 argument, however, the Court finds that oral argument will not aid in the determination of 24 the Motion and is therefore unnecessary.1 25 II. 26 To survive a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6), 27 “a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to 28 1 Also sued are several minor Defendants, who are alleged to have harassed and assaulted KJ, along with their parents. These Defendants did not join in this Motion. 1 relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting 2 Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)); see also Fed. R. Civ. P. 8. A claim 3 is facially plausible when it contains “factual content that allows the court to draw the 4 reasonable inference” that the moving party is liable. Iqbal, 556 U.S. at 678. At the pleading 5 stage, the Court’s duty is to accept all well-pleaded complaint allegations as true. Id. Facts 6 should be viewed “in the light most favorable to the non-moving party.” Faulkner v. ADT 7 Sec. Servs., Inc., 706 F.3d 1017, 1019 (9th Cir. 2013). “[D]ismissal . . . is proper if there is 8 a lack of a cognizable legal theory or the absence of sufficient facts alleged under a 9 cognizable legal theory.” Conservation Force v. Salazar, 646 F.3d 1240, 1242 (9th Cir. 10 2011) (quoting Balisteri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 1988)) 11 (internal marks omitted). 12 III. 13 A. 14 In Count IX of the Amended Complaint, Plaintiffs Jeremy and Latonia Johnson, 15 KJ’s parents, assert an Arizona common-law claim for loss of consortium arising from their 16 son’s injuries.2 The CUSD Defendants move to dismiss with prejudice, arguing that this 17 claim is untimely under Arizona’s one-year statute of limitations for claims against public 18 entities and employees. A.R.S. § 12-821; Lee v. City of Kingman, 124 F. Supp. 3d 985, 992 19 (D. Ariz. 2015) (holding that a claim for loss of consortium against municipal defendants 20 is governed by Arizona’s one-year statute of limitations for actions against government 21 entities and employees). 22 Plaintiffs argue that the statute of limitations was tolled while they tried to negotiate 23 a settlement before filing this lawsuit, citing A.R.S. § 12-821.01(C). But that statute applies 24 only when the 180-day notice of claim deadline is tolled for a mandatory dispute resolution 25 or administrative review process. That is not the case here, as Plaintiffs have not shown 26 any mandatory dispute resolution or administrative review process applicable to their loss 27 of consortium claim against the CUSD Defendants. Plaintiffs’ argument that dismissing

28 2 Plaintiff KJ’s loss of consortium claim, asserted in Count IX, is not subject to the Motion to Dismiss. 1 their loss of consortium claim results in piecemeal litigation also misses the mark because 2 there is no other litigation relating to the parents’ loss of consortium claim. 3 The Court finds that the one-year statute of limitations bars the parents’ loss of 4 consortium claim. This finding is based on the allegations of the Amended Complaint, 5 which alleges multiple instances of abuse from August 2021 through March 2022. (Doc. 6 33 ¶¶ 40-51) The Amended Complaint contends that KJ’s parents reported the abuse to the 7 CUSD Defendants and others during this period. (Id. ¶¶ 41-43, 46) This action was filed 8 on March 12, 2024, about two years after the alleged last date of abuse. Plaintiffs Jeremy 9 and Latonia Johnson’s loss of consortium claim against the CUSD Defendants is time- 10 barred. Count IX will be dismissed with prejudice because no pleading amendment can 11 cure this legal deficiency. 12 B. 13 The CUSD Defendants next move to dismiss Counts I, II, and IV of the Amended 14 Complaint. Count I asserts a Fourteenth Amendment due process civil rights claim that 15 Defendants breached a duty to protect KJ from harm while on school property during the 16 school day and on and off school property during extracurricular activities. (Doc. 33 ¶ 69) 17 Count II asserts a municipal liability claim against Defendant Chandler Unified School 18 District for “failure to properly train, supervise, control, and discipline the individual 19 employee Defendants.” (Id. ¶ 82) Finally, Count IV asserts a Fourteenth Amendment due 20 process claim against the individual employee Defendants—Franklin, Hickey, Culver, 21 Garretson, Boyd, and Narducci—claiming that they conspired with one another to prevent 22 the minor Defendants’ alleged misconduct to the proper authorities. (Id. ¶ 96) These claims 23 are brought under the Civil Rights Act, 42 U.S.C. § 1983. According to the CUSD 24 Defendants, these claims for relief should be dismissed because the Amended Complaint 25 fails to allege that they had a constitutional duty to protect KJ and that there are no well- 26 pleaded facts to support the elements required to prove liability. 27 1. 28 The Supreme Court has held that the due process clause does not obligate state 1 officials to protect individuals from violence. DeShaney v. Winnebago Cnty. Dep’t. of Soc. 2 Servs., 489 U.S. 189, 195 (1989); see also Patel v. Kent Sch. Dist., 648 F.3d 965, 971 (9th 3 Cir. 2011) (“[T]he Fourteenth Amendment’s Due Process Clause generally does not confer 4 any affirmative right to government aid, even where such aid may be necessary to secure 5 life, liberty, or property interests.”). In DeShaney, a four-year-old was beaten so severely 6 by his father that the child was expected to live his entire life in an institution. 489 U.S. at 7 193. Prior to this, the child’s stepmother notified the county’s child protective services 8 division of suspected physical abuse. Id. at 192.

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Bluebook (online)
Johnson v. Chandler Unified School District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/johnson-v-chandler-unified-school-district-azd-2024.