Russellville School District v. Doe

CourtDistrict Court, E.D. Arkansas
DecidedSeptember 22, 2021
Docket4:20-cv-00722
StatusUnknown

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

Bluebook
Russellville School District v. Doe, (E.D. Ark. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS CENTRAL DIVISION

RUSSELLVILLE SCHOOL DISTRICT PLAINTIFF

v. Case No. 4:20-cv-00722 KGB

T. R., Parent and Next Friend of K.R., a Minor DEFENDANT

ORDER Before the Court are the motion to dismiss amended complaint and motion for leave to file a reply brief of defendants T.R., individually and as parent and next friend of K.R., a minor (“defendants”) (Dkt. Nos. 8, 15). For good cause shown, the Court grants defendants’ motion for leave to file a reply brief, directs defendants to file their reply within 14 days from entry of this Order, and has considered their proposed reply when ruling on the pending motion (Dkt. No. 15). For the reasons that follow, the Court denies defendants’ motion to dismiss the amended complaint of plaintiff Russellville School District (“RSD”) (Dkt. No. 8). I. Background Defendants move to dismiss RSD’s amended complaint. Specifically, defendants argue that RSD’s appeal of the hearing officer’s decision in case no. H-20-09, brought under the Individuals with Disabilities Education Act (“IDEA”), is now moot because RSD has implemented fully all of the material terms of the hearing officer’s order (Dkt. No. 8, ¶¶ 1-3). RSD responded in opposition to defendants’ motion to dismiss the amended complaint as moot claiming that it had not yet complied fully with the hearing officer’s order and that the case is excepted from the mootness doctrine as it is “capable of repetition yet evading review.” (Dkt. No. 13). Defendants move for leave to file a reply brief to address specific arguments raised by RSD in its response to the motion to dismiss (Dkt. Nos. 15, 15-1). For good cause shown, the Court grants defendants’ motion for leave to file a reply brief, directs defendants to file their reply within 14 days from entry of this Order, and has considered their proposed reply when ruling on the pending motion (Id.).

Defendants also filed an answer to the amended complaint and counterclaim in which they seek attorneys’ fees and costs as the prevailing party in a proceeding under the IDEA and also “compensatory damages for their pecuniary and non-pecuniary losses in an amount determined by a jury” (Dkt. No. 16, at 11). The Court notes that in Doe v. Russellville School District, et al., Case No. 4:20-cv-00735-KGB, defendants also seek attorneys’ fees and costs associated with their appeal of administrative case no. H-20-09 RSD has filed the administrative record of the hearing in case no. H-20-09 with the Court (Dkt. No. 22, ¶ 3). In its latest status report, RSD states that it intends to file a motion to amend its complaint to include an appeal of an additional hearing officer’s final decision and an order

issued July 3, 2021, in two additional due process hearings filed by defendants against RSD (Id.). II. Legal Standard To survive a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), “a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). A claim is facially plausible “when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. (citing Twombly, 550 U.S. at 556). “While a complaint attacked by a [Federal] Rule [of Civil Procedure] 12(b)(6) motion to dismiss does not need detailed factual 2 allegations, a plaintiff’s obligation to provide the ‘grounds’ of his ‘entitle[ment] to relief’ requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do.” Twombly, 550 U.S. at 555 (alteration in original) (citations omitted). “[T]he complaint must contain facts which state a claim as a matter of law and must not be conclusory.” Briehl v. Gen. Motors Corp., 172 F.3d 623, 627 (8th Cir. 1999).

“When ruling on a motion to dismiss, the district court must accept the allegations contained in the complaint as true and all reasonable inferences from the complaint must be drawn in favor of the nonmoving party.” Young v. City of St. Charles, 244 F.3d 623, 627 (8th Cir. 2001). The Court may, however, “consider the pleadings themselves, materials embraced by the pleadings, exhibits attached to the pleadings, and matters of public record.” Roe v. Nebraska, 861 F.3d 785, 788 (8th Cir. 2017). A reviewing court “may consider these materials without converting the defendant’s request to a motion for summary judgment.” Roe, 861 F.3d at 788 (citations and quotation marks omitted); see Lustgraaf v. Behrens, 619 F.3d 867, 885–86 (8th Cir. 2010) (“[W]hen considering a motion to dismiss . . . , [a court] may take judicial notice (for the purpose

of determining what statements the documents contain and not to prove the truth of the documents’ contents) of relevant public documents[.]” (alterations in original) (emphasis omitted)). “Article III of the United States Constitution limits the jurisdiction of the federal courts to actual, ongoing cases and controversies.” Haden v. Pelofsky, 212 F.3d 466, 469 (8th Cir. 2000). “When, during the course of litigation, the issues presented in a case ‘lose their life because of the passage of time or a change in circumstances . . . and a federal court can no longer grant effective relief,’ the case is considered moot.” Ali v. Cangemi, 419 F.3d 722, 723 (8th Cir. 2005) (quoting Haden, 212 F.3d at 469).

3 III. Analysis In their due process hearing complaint in case no. H-20-09, defendants alleged procedural and substantive violations of the IDEA. In a March 9, 2020, decision, the hearing officer found that RSD denied K.R. a free appropriate public education (“FAPE”) for the period from May 2019 to September 23, 2019, because RSD did not include sufficient behavioral supports on K.R.’s

individualized education program (“IEP”). The hearing officer ordered RSD to take the following actions: 1. Contact a B[oard] C[ertified] B[ehavioral] A[nalyst] [(“BCBA”)] within fifteen (15) days of the date of this decision and make arrangements for (1) a full behavioral evaluation to be conducted for Student and, (2) a program to address Student’s behavioral issues going forward. Should the program recommended by the BCBA include ABA therapy, District shall provide this therapy to Student in accordance with the behavioral program. District shall revise Student’s IEP to reflect the BCBA evaluation and the updated program recommended by the evaluator.

2. Revise Student’s IEP to reflect a change in Student’s placement from the ALE to a classroom appropriate for Student in light of his circumstances. Student’s IEP team shall meet to discuss whether Student would be best served in a traditional general education classroom with supports, or in a self-contained classroom. District and Parent will meet prior to the implementation of this change in placement and agree to a transition plan for Student. Following this change in placement Student’s IEP team will meet every three (3) months for the first year to reevaluate whether the new placement is, in fact, appropriate for Student.

3.

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Lustgraaf v. Behrens
619 F.3d 867 (Eighth Circuit, 2010)
Briehl v. General Motors Corporation
172 F.3d 623 (Eighth Circuit, 1999)
Henry Roe v. State of Nebraska
861 F.3d 785 (Eighth Circuit, 2017)
Jefferson County Board of Education v. Bryan M.
706 F. App'x 510 (Eleventh Circuit, 2017)

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Russellville School District v. Doe, Counsel Stack Legal Research, https://law.counselstack.com/opinion/russellville-school-district-v-doe-ared-2021.