Sanchez v. Binghamton City School District

CourtCourt of Appeals for the Second Circuit
DecidedAugust 15, 2025
Docket24-2125
StatusUnpublished

This text of Sanchez v. Binghamton City School District (Sanchez v. Binghamton City School District) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sanchez v. Binghamton City School District, (2d Cir. 2025).

Opinion

24-2125 Sanchez v. Binghamton City School District

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 15th day of August, two thousand twenty-five.

Present:

JON O. NEWMAN, WILLIAM J. NARDINI, EUNICE C. LEE, Circuit Judges. ____________________________________

IVANIS SANCHEZ, JANIS BRISTOL, ISIS MCKINSTRY, ANASIA SANKS,

Plaintiffs-Appellants,

v. 24-2125-cv

BINGHAMTON CITY SCHOOL DISTRICT, BINGHAMTON BOARD OF EDUCATION, TIM SIMONDS, IN HIS INDIVIDUAL AND OFFICIAL CAPACITY, MICHELLE RALEIGH, IN HER INDIVIDUAL AND OFFICIAL CAPACITY, MARY ELLEN EGGLESTON, IN HER INDIVIDUAL AND OFFICIAL CAPACITY,

Defendants-Appellees. _____________________________________

1 For Plaintiffs-Appellants: KATRINA FELDKAMP, NAACP Legal Defense and Educational Fund, Inc., New York, NY (Samuel Spital, Rachel Kleinman, Pilar Whitaker, Avatara Smith-Carrington, NAACP Legal Defense and Educational Fund, Inc., New York, NY, and Washington, DC, Jamie A. Levitt, Morrison & Foerster LLP, New York, NY, on the brief).

For Defendants-Appellees: SHANNON T. O’CONNOR (Jennifer R. Collesano, Alice Cunningham, on the brief), Kenney Shelton Liptak Nowak LLP, Buffalo, NY.

Appeal from a judgment of the United States District Court for the Northern District of

New York (Glenn T. Suddaby, District Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND

DECREED that the judgment of the district court is AFFIRMED.

Plaintiffs-Appellants Ivanis Sanchez, Janis Bristol, Isis McKinstry, and Anasia Sanks

appeal from a judgment of the United States District Court for the Northern District of New York

(Glenn T. Suddaby, District Judge), entered on July 15, 2024, in favor of Defendants-Appellees

Binghamton City School District, Binghamton Board of Education, Principal Tim Simonds,

Assistant Principal Michelle Raleigh, and School Nurse Mary Ellen Eggleston. The Plaintiffs

brought this action alleging, inter alia, that Simonds, Raleigh, and Eggleston violated their rights

under the Fourth Amendment to the U.S. Constitution by subjecting them to invasive searches

when they were students at East Middle School. On February 1, 2024, the district court entered

an order granting in part the Defendants’ request for summary judgment. As pertinent here, the

district court dismissed each of the Plaintiffs’ Fourth Amendment claims, except for McKinstry’s

Fourth Amendment claim against Eggleston. On July 15, 2024, McKinstry agreed to dismiss that

claim with prejudice but preserved her right to appeal the district court’s summary judgment ruling

2 as to her other claims. The district court subsequently entered judgment and dismissed the case.

On appeal, the Plaintiffs challenge the district court’s February 1, 2024, order to the extent it

granted summary judgment to the Defendants on the Plaintiffs’ Fourth Amendment claims. We

assume the parties’ familiarity with the case.

“We review de novo a district court’s grant or denial of summary judgment, viewing the

record in the light most favorable to the party against whom summary judgment is sought.”

Mullins v. City of New York, 653 F.3d 104, 113 (2d Cir. 2011). 1 Summary judgment is appropriate

when “there is no genuine dispute as to any material fact and the movant is entitled to judgment

as a matter of law.” Truitt v. Salisbury Bank & Tr. Co., 52 F.4th 80, 85 (2d Cir. 2022).

“Fourth Amendment rights are different in public schools than elsewhere . . . .” Bd. of

Educ. of Indep. Sch. Dist. No. 92 of Pottawatomie Cnty. v. Earls, 536 U.S. 822, 829–30 (2002).

Although the Fourth Amendment’s “prohibition on unreasonable searches and seizures applies to

searches conducted by public school officials,” New Jersey v. T.L.O., 469 U.S. 325, 333 (1985),

the reasonableness inquiry for such searches must account for “the schools’ custodial and tutelary

responsibility for children,” Earls, 536 U.S. at 830. As a result, we apply a standard of reasonable

suspicion, rather than probable cause, to student searches, Safford Unified Sch. Dist. No. 1 v.

Redding, 557 U.S. 364, 370 (2009), assessing the totality of the circumstances to determine

whether the search was “justified at its inception” and “reasonably related in scope to the

circumstances which justified the interference in the first place,” T.L.O., 469 U.S. at 341; see also

Phaneuf v. Fraikin, 448 F.3d 591, 597 (2d Cir. 2006). “Under ordinary circumstances, a search

of a student by a teacher or other school official will be justified at its inception when there are

1 Unless otherwise indicated, when quoting cases, all internal quotation marks, alteration marks, emphases, footnotes, and citations are omitted. 3 reasonable grounds for suspecting that the search will turn up evidence that the student has violated

or is violating either the law or the rules of the school.” T.L.O., 469 U.S. at 341–42. “Such a

search will be permissible in its scope when the measures adopted are reasonably related to the

objectives of the search and not excessively intrusive in light of the age and sex of the student and

the nature of the infraction.” Id. at 342. Applying these principles, we discern no error in the

district court’s summary judgment ruling on the Plaintiffs’ Fourth Amendment claims.

First, we agree with the district court that no reasonable jury could find that the Defendants

lacked sufficient justification to begin searching the Plaintiffs. In making this determination, we

consider “only those facts known to the school officials prior to the search[es].” Phaneuf,

448 F.3d at 597. The record shows that in the month preceding the searches, the Binghamton City

School District had expressed concerns about reports of students ingesting a “purple” juice

consisting of “codeine-based prescription cough syrup, soda and candy” that can cause “dizziness,

drowsiness, abdominal pain, loss of balance or coordination, slow/slurred speech, constricted

pupils, difficulty breathing, blurred vision, nausea, slowed heart rate, and memory problems,” as

well as seizures, coma, and death. App’x at 783, 785. On the day the Plaintiffs were searched,

school officials were unable to locate them for several minutes after they left the cafeteria. As

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