Sadler v. Greenville Independent School District

CourtDistrict Court, N.D. Texas
DecidedFebruary 14, 2020
Docket3:19-cv-01551
StatusUnknown

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

Bluebook
Sadler v. Greenville Independent School District, (N.D. Tex. 2020).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION TERRY SADLER AND § THREESA SADLER, as Next § Friend of JOHN DOE, a Minor, § , § Civil Action No. 3:19-CV-01551-X § v. § § GREENVILLE INDEPENDENT § SCHOOL DISTRICT, § § § . § MEMORANDUM OPINION AND ORDER This lawsuit stems from repeated, student-to-student sexual assault at an elementary school in Greenville ISD. The parents of the alleged victim sued Greenville ISD for violations of 42 U.S.C. § 1983 and Title IX (20 U.S.C. § 1681), seeking injunctive relief, compensatory damages, and attorney’s fees. The 1983 claims include one for a substantive due process right to bodily integrity, failure to supervise school employees, and failure to train school employees. The Title IX allegations allege a claim for student-to-student harassment and a claim for failures to have policies that prevented the abuse. Greenville ISD moved to dismiss all but the Title IX claim for student-to-student sex discrimination [Doc. No. 7], and that motion is now ripe. The Court GRANTS the motion to dismiss and DISMISSES WITH PREJUDICE: 1 the alleged abuser and swears that he is not allowed to use the restroom

when other children are in it. 2. The substantive Due Process claim to bodily integrity. The Supreme Court has held that such claims extend to harm by government actors, not government protection from harm by private actors. 3. The failure to supervise claim under Section 1983. If there is no underlying constitutional violation, there can be no viable 1983 claim. 4. The failure to train claim under Section 1983. If there is no underlying

constitutional violation, there can be no viable 1983 claim. 5. The Title IX policies claim. The Supreme Court has held that a failure to have sufficient policies violates an agency regulation, not a Congressional law, and does not give rise to a Title IX claim for money damages. Nonetheless, the core of the parents’ case remains: The Title IX student-to-student

sexual harassment claim. I. Factual Background The parents claim that a Greenville ISD employee saw a student touching their child’s penis and forcing him to masturbate against his will when they were in the restroom. After a meeting with school officials, the officials told the parents they would report the unlawful conduct as required by law and craft and implement a safety plan for Doe. Greenville ISD reported the incident to Child Protective Services

but not to law enforcement. The misconduct occurred again. The principal allegedly 2 enforcement or implemented a safety plan. The assistant superintendent believed

the matter had been reported and the school had implemented a safety plan. The parents, as next friends of their child identified in this proceeding as John Doe, sued Greenville ISD for violations of 42 U.S.C. § 1983 and Title IX (20 U.S.C. § 1681), seeking injunctive relief, compensatory damages, and attorney’s fees. The 1983 claims include substantive due process right to bodily integrity, failure to supervise school employees, and failure to train school employees. The Title IX claims allege a claim for student-to-student harassment and a claim for failures to have

policies that prevented the abuse. Greenville ISD moved to dismiss all but the Title IX claim for student-to-student sex discrimination [Doc. No. 7], and that partial motion to dismiss is now ripe. II. Motion to Dismiss Standard A court must dismiss a claim for which it lacks jurisdiction. FED. R. CIV. P. 12(b)(1). When a Rule 12(b)(1) motion is filed along with other Rule 12 motions, the Court should consider the Rule 12(b)(1) jurisdictional attack first.1 A factual attack

can allow the Court to go beyond the pleadings.2 And the Court can resolve disputed facts. , 281 F.3d at 659. The party asserting jurisdiction bears the burden of proof for a motion under Rule 12(b)(1).3

1 , 281 F.3d 158, 161 (5th Cir. 2001). 2 , 613 F.2d 507, 511 (5th Cir. 1980). 3 at 161.

3 pleadings by “accepting as true the factual allegations in the complaint and drawing all inferences in the plaintiff’s favor.”4 To survive a motion to dismiss, the parents

must allege enough facts “to state a claim to relief that is plausible on its face.”5 “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.”6 “The plausibility standard is not akin to a ‘probability requirement,’ but it asks for more than a sheer possibility that a defendant has acted unlawfully.”7 “[W]here the well-pleaded facts do not permit the court to infer more than the mere

possibility of misconduct, the complaint has alleged—but it has not ‘show[n]’—‘that the pleader is entitled to relief.’”8 III. Analysis Greenville ISD moved to dismiss: (1) the remedy of injunctive relief due to lack of standing, (2) the substantive due process claim, (3) the failure to supervise claim, (4) the failure to train claim, and (5) the Title IX claim for failure to have appropriate

policies. [Doc. No. 7]. The school district did not move to dismiss the Title IX student- to-student discrimination claim.

4 , 807 F.3d 541, 544 (2d Cir. 2015) (citing , 622 F.3d 104, 110–11 (2d Cir. 2012)). 5 , 550 U.S. 544, 570 (2007). 6 , 556 U.S. 662, 678 (2009). 7 ; , 550 U.S. at 545 (“Factual allegations must be enough to raise a right to relief above the speculative level[.]”). 8 , 556 U.S. at 679 (quoting Fed. R. Civ. P. Rule 8(a)(2)). 4 To have standing to seek injunctive relief, the Sadlers must show “there is a real and immediate threat of repeated injury.”9 Greenville ISD submitted evidence

that it: (1) permanently transferred the other student involved in the alleged sexual assaults to a different campus on March 29, 2019; and (2) implemented a procedure to prevent this other student from being in a restroom at the same time as any other student. The parents do not dispute this evidence but contend that the promise to keep the alleged abuser out of restrooms when other students are in them is a hollow promise and that there still could be other opportunities for John Doe’s abuser to

contact him in private. The Court respectfully disagrees that these concerns confer standing to seek an injunction. Greeneville ISD has now made a promise to the Court that the situation will not reoccur on school grounds. If Greenville ISD breaks that promise, the parents are at liberty to seek injunctive and any other appropriate relief at that time. In any event, the scope of permissible injunctive relief could not extend to

ensuring that Greenville ISD prevent such opportunities not on school property. Because there is no longer a real and immediate threat of injury because of the school district’s steps, Doe now lacks standing to seek injunctive relief. , 881 F.3d at 366.

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

Related

Cite This Page — Counsel Stack

Bluebook (online)
Sadler v. Greenville Independent School District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sadler-v-greenville-independent-school-district-txnd-2020.