Lou Anne R. Young (Parent), for and on behalf of “J.Y.,” minor child (Student) v. Minidoka County School District #331

CourtDistrict Court, D. Idaho
DecidedJune 16, 2026
Docket4:24-cv-00277
StatusUnknown

This text of Lou Anne R. Young (Parent), for and on behalf of “J.Y.,” minor child (Student) v. Minidoka County School District #331 (Lou Anne R. Young (Parent), for and on behalf of “J.Y.,” minor child (Student) v. Minidoka County School District #331) is published on Counsel Stack Legal Research, covering District Court, D. Idaho primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lou Anne R. Young (Parent), for and on behalf of “J.Y.,” minor child (Student) v. Minidoka County School District #331, (D. Idaho 2026).

Opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF IDAHO

LOU ANNE R. YOUNG (Parent), for and on behalf of “J.Y.,” minor child (Student), Case No. 4:24-cv-00277-AKB

Plaintiffs, MEMORANDUM DECISION AND ORDER

v.

MINIDOKA COUNTY SCHOOL

DISTRICT #331,

Defendant.

Pending before the Court are Plaintiffs’ Motion to Quash Subpoenas (Dkt. 39), Plaintiffs’ Motion to Quash Subpoena for Deposition of J.Y. (Dkt. 42), Defendant Minidoka County School District #331’s Motion to Require J.Y. to Prosecute His Own Claims Pursuant to Federal Rule of Civil Procedure 17 (Dkt. 45), Defendant’s Motion to Remove Pseudonym (Dkt. 46), and Defendant’s Motion to Compel Testimony of LouAnne R. Young (Dkt. 47). Having reviewed the record and the parties’ submissions, the Court finds that the facts and legal argument are adequately presented and that oral argument would not significantly aid its decision-making process, and it decides the motions on the parties’ briefing. Dist. Idaho Loc. Civ. R. 7.1(d)(1)(B); see also Fed. R. Civ. P. 78(b). For the reasons set forth below, the Court denies Plaintiffs’ Motion to Quash Subpoenas as moot; denies Plaintiffs’ Motion to Quash Subpoena for Deposition of J.Y.; grants in part and denies in part Defendant’s Rule 17 motion; denies without prejudice Defendant’s Motion to Remove Pseudonym; and grants Defendant’s Motion to Compel Testimony of LouAnne R. Young. The Court declines to award attorney fees or expenses. I. BACKGROUND

Plaintiff Lou Anne R. Young filed this action against Defendant Minidoka County School District #331 “individually and on behalf of her son, JY” (Dkt. 1 at 1). Plaintiffs seek review of an adverse IDEA due process decision and assert additional claims under § 504 of the Rehabilitation Act, Title II of the ADA, 42 U.S.C. § 1983, and the Idaho Constitution (Dkt. 1 at 1-4, 17-81). According to the Complaint, J.Y. has qualified for special education since age three and has medical conditions, reduced cognitive ability, memory deficits, and adaptive and functional limitations affecting his education (Dkt. 1 at 5-6). J.Y. also has social, emotional, and behavioral needs related to anxiety, fear, peer relationships, attention, and school functioning (Dkt. 1 at 6-7). Plaintiffs claim the District failed to provide adequate special-education services, to adequately address bullying, and to conduct or implement appropriate behavioral assessments and interventions and denied J.Y. a free, appropriate public education (Dkt. 1 at 6-7, 10-17). The Complaint also concerns an incident on January 5, 2023, involving a firearm. J.Y. allegedly took a gun from his parents’ home, hid it in a field off campus, and sent another student

a photograph of the gun with the message, “I got gun rn” (Dkt. 1 at 8). Plaintiffs allege that J.Y. did not threaten anyone with the gun and that no one at school saw the gun, and the parties dispute whether the gun was ever on school grounds (Dkt. 1 at 8). J.Y. was arrested after the gun was recovered, and Plaintiffs allege the resulting charge was later resolved with probation and fines (Dkt. 1 at 8). Plaintiffs challenge the disciplinary process that followed, including the IDEA manifestation-determination reviews and expulsion proceedings (Dkt. 1 at 8-13). Plaintiffs seek injunctive relief, compensatory education, mental-health services, a special- needs trust, damages, and attorney fees (Dkt. 1 at 81-83). The requested relief includes $400,000 in “compensatory and special damages,” compensatory education through J.Y.’s twenty-first birthday, ongoing mental-health services, and funding for a special-needs trust (Dkt. 1 at 81-82). J.Y. has since turned eighteen (Dkt. 47-3 at 5). Ms. Young testified at deposition that J.Y. was eighteen years old and that his birthday is January 28, 2008. (Dkt. 47-3 at 5.) Defendant

represents that J.Y. is not under a guardianship or conservatorship and that the case caption has not been amended since filing (Dkt. 45 at 1). For this reason, Defendant moves to require J.Y. to prosecute his own claims and to remove his pseudonym. Defendant also moves to compel Ms. Young’s continued deposition, and Plaintiffs move to prevent J.Y.’s deposition. II. ANALYSIS A. Real Party in Interest, Representative Capacity, and Proceeding in Pseudonym 1. Legal Standard Rule 10(a) of the Federal Rules of Civil Procedure provides that “the title of the complaint must name all the parties.” “The normal presumption in litigation is that the parties must use their real names.” Doe v. Kamehameha Sch./Bernice Pauahi Bishop Est., 596 F.3d 1036, 1042 (9th Cir.

2010). Similarly, Rule 17(a)(1) requires that “an action must be prosecuted in the name of the real party in interest,” meaning the person who, under the governing substantive law, possesses the right being enforced. Dunmore v. United States, 358 F.3d 1107, 1112 (9th Cir. 2004). Rule 17(c)(2) provides an exception and allows a minor or incompetent person, who lacks a duly appointed representative, to sue through a next friend or guardian ad litem. In that posture, the child’s claims remain the child’s claims; the representative supplies procedural capacity and protection; but the representative does not become the owner of the child’s claims. Dacanay v. Mendoza, 573 F.2d 1075, 1079-80 (9th Cir. 1978) (explaining guardian ad litem or next friend is court officer and may not prejudice minor’s substantial rights without court approval). In an IDEA case, parents may have independent rights under the IDEA. Winkelman ex rel. Winkelman v. Parma City Sch. Dist., 550 U.S. 516, 529-33 (2007). However, that fact does not convert a child’s separate claims into the parent’s claims. Keates v. Koile, 846 F. App’x 628, 629 n.1 (9th Cir. 2021) (noting minor reached majority, voluntarily withdrew claims, and parent proceeded to trial on

individual claims). Similarly, a court may permit a plaintiff to proceed using a pseudonym in various circumstances, including when: “(1) identification creates a risk of retaliatory physical or mental harm, (2) anonymity is necessary to preserve privacy in a matter of sensitive and highly personal nature, and (3) the anonymous party would be compelled . . . to admit [his] intention to engage in illegal conduct, thereby risking criminal prosecution.” Does I thru XXIII v. Advanced Textile Corp., 214 F.3d 1058, 1068 (9th Cir. 2000) (internal quotation marks omitted). In determining whether to allow a party to proceed anonymously over the opposing party’s objection, a court balances “the severity of the threatened harm, the reasonableness of the anonymous party’s fears, and the anonymous party’s vulnerability to such retaliation,” against “the prejudice to the opposing

party and the public’s interest in knowing the party’s identity.” Id. 2. Real Party in Interest Defendant moved to require J.Y. to prosecute his own claims under Rule 17 (Dkt. 45). Defendant contends J.Y.

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

Related

Ernest Lee Allen v. Art Calderon
408 F.3d 1150 (Ninth Circuit, 2005)
Johns v. County of San Diego
114 F.3d 874 (Ninth Circuit, 1997)
Does I thru XXIII v. Advanced Textile Corp.
214 F.3d 1058 (Ninth Circuit, 2000)
Krain v. Smallwood
880 F.2d 1119 (Ninth Circuit, 1989)
United States v. Ahmed Alahmedalabdaloklah
94 F.4th 782 (Ninth Circuit, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
Lou Anne R. Young (Parent), for and on behalf of “J.Y.,” minor child (Student) v. Minidoka County School District #331, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lou-anne-r-young-parent-for-and-on-behalf-of-jy-minor-child-idd-2026.