Virginia State Conference NAACP v. County School Board of Shenandoah County

District Court, W.D. Virginia·Decided June 5, 2025·No. 5:24-cv-00040·Unknown

Opinion

CLERKS OFFICE US DISTRICT COURT IN THE UNITED STATES DISTRICT COURT —ATHARRISONBuRG, vA FOR THE WESTERN DISTRICT OF VIRGINIA 06/05/2025 HARRISONBURG DIVISION (AURA A. aon, Come By: /s/ Amy Fansler VIRGINIA STATE CONFERENCE _) DEPUTY CLERK NAACP et al., ) ) Plaintiffs, ) ) v. ) Case No. 5:24-cv-040 ) COUNTY SCHOOL BOARD OF ) By: Michael F. Urbanski SHENANDOAH COUNTY, ) Senior United States District Judge ) Defendant. ) MEMORANDUM OPINION In this case, plaintiffs seek declaratory and injunctive relief from defendant County School Board of Shenandoah County’s decision to rename schools in honor of Confederate leaders, a decision plaintiffs allege violates their rights under the First Amendment, Fourteenth Amendment, Title VI of the Civil Rights Act (“Title VI”), and the Equal Educational Opportunities Act “EEOA”). Compl., ECF No. 1. On March 6, 2025, the School Board filed a demand for a trial by jury under Federal Rule of Civil Procedure (“Rule”) 38(b)(2). ECF No. 74. On March 27, 2025, plainuffs moved to strike the jury demand. ECF No. 86. The court must now determine whether there is a federal right to a jury trial in this case. In the absence of a statute conferring a right to a trial by jury, the Seventh Amendment jury trial right hinges on a suit being “at common law.” U.S. Const. amend. VII. Because plaintiffs seek only equitable relief in the form of injunctive relief and corresponding declaratory relief and attorneys’ fees and litigation costs, not damages or any other legal remedy, no jury trial right is triggered in this case. Accordingly, plaintiffs’ motion to strike the jury demand is GRANTED.

I. This matter arises out of the School Board’s 2024 decision to reinstate the names Stonewall Jackson High School and Ashby Lee Elementary School. Compl., ECF No. 1. The School Board had previously decided in 2020-2021 to retire these names because they referred to leaders of the Confederacy, and for several years, the schools operated as Mountain View High School and Honey Run Elementary School. Id. {| 6-7. Plaintiffs are parents of children who attend or will attend Stonewall Jackson High School and Ashby Lee Elementary School; these individual plaintiffs are joined by the Virginia State Conference NAACP, an association whose membership also includes families with students attending these schools. Id. {[f] 18-27. Plaintiffs allege that certain students object to the message conveyed by these Confederate school names and that Black students disproportionately suffer dignitary and educational harms due to these Confederate school names. Id. On June 11, 2024, plaintiffs filed their complaint challenging the School Board’s 2024 decision under the First Amendment, Fourteenth Amendment, Title VI, and the EEOA. Id. §| 14. The complaint seeks the following forms of relief: (1) declaratory relief stating “that [the School Board] is violating the Fourteenth Amendment and First Amendment of the United States Constitution, Title VI of the Civil Rights Act of 1964, and the Equal Educational Opportunities Act by maintaining and reinstating the school names Stonewall Jackson [High School] and Ashby Lee [Elementary School], and the team name/mascot the ‘Generals;”” (2) injunctive relief requiring the School Board to remove the Confederate names and mascots and preventing renaming these schools after Confederate leaders in the future; (3) injunctive relief requiring the School Board to remove all vestiges of the dual school system previously

operated in Shenandoah County; (4) attorneys’ fees under 42 U.S.C. § 1988; (5) litigation costs pursuant to 28 U.S.C. § 1920 and 42 U.S.C. § 1988; and (6) any other relief the court deems appropriate. Id. at Conclusion and Relief Requested. Plaintiffs do not seek damages of any kind. Id. Defendants moved to dismiss the complaint for failure to state a claim on July 17, 2024. ECF No. 29. In a memorandum opinion and order dated January 22, 2025, the court denied the motion to dismiss. ECF No. 62; ECF No. 63. The School Board filed its answer to the complaint on February 28, 2025, ECF No. 73, and its jury demand on March 6, 2025, ECF No. 74. A status conference was held on March 12, 2025. ECF No. 79. At that time, the parties and court discussed the possibility of setting a special timeline for the case to allow dispositive motions on plaintiffs’ First Amendment claim to be briefed and argued in advance of discovery being completed on plaintiffs’ Equal Protection, Title VI, and EEOA claims. The parties then submitted an agreed scheduling order, which the court entered. ECF No. 97. Accordingly, no trial date is currently set, but a hearing on dispositive motions as to the First Amendment claim is set for July 1, 2025, at 2:00 p.m. in Harrisonburg, ECF No. 112, and a status conference is scheduled for August 26, 2025, at 2:00 p.m. in Harrisonburg, ECF No. 108. Plaintiffs filed the instant motion to strike the School Board’s jury demand on March 27, 2025. ECF No. 86. Plaintiffs contend that any trial that may ultimately take place in this matter is not properly subject to the School Board’s jury demand because this is a suit in equity seeking injunctive relief and declaratory relief coextensive with that injunctive relief, not a suit at common law seeking damages. ECF No. 87. On April 10, 2025, the School Board responded in opposition to the motion to strike. ECF No. 100. Although the School Board

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agrees that “there is no right to a jury trial in cases involving purely equitable relief, and actions for injunctive relief are inherently equitable,” the School Board argues that the claims here are legal in nature for three reasons: (1) because the declaratory relief at issue is analogous to a claim for damages under 42 U.S.C. § 1983 (“Section 1983”), (2) because plaintiffs’ request for attorneys’ fees and litigation costs makes this action akin to an acuon for damages, and (3) because compliance with the injunction plaintiffs seek would cost the School Board money. Id. at 1. Plaintiffs replied on April 17, 2025. ECF No. 101. The motion to strike is now ripe for the court’s review. II. Under Rule 38(b), “[o]n any issue triable of right by a jury, a party may demand a jury trial” by timely serving the other parties and filing a written demand. Fed. R. Civ. P. 38(b). When a jury trial has been demanded in compliance with Rule 38, the “trial on all issues so demanded must be by jury unless” the parties later stipulate to a nonjury trial or “the court, on motion or on its own, finds that on some or all of those issues there is no federal right to a jury trial.” Fed. R. Civ. P. 39(a). To determine whether there is a federal right to a jury trial, the court considers both the Seventh Amendment and the statutes at issue. See Israelitt □□ Enter. Servs. LLC, 78 F.4th 647, 657 (4th Cir. 2023) (“The right to a jury trial can stem from a statute itself... □ When the statute provides no such right, the Seventh Amendment might

Here, plaintiffs are proceeding under three statutes: Title VI, the EEOA, and Section 1983. It is well-settled that Title VI does not independently create a jury trial right. See Jenkins y. Skinner, 771 F. Supp. 133, 135 (B.D. Va. 1991) (“Titles VI and VII[] are silent as to the

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