A.T. v. Dry Creek Joint Elementary School District
2:16-cv-02925
| E.D. Cal. | Jun 20, 2017Background
- Plaintiff A.T., a minor with ADHD and bipolar disorder, was placed at Secret Ravine School (operated by Placer County Office of Education) and subject to repeated physical restraints and isolation per an IEP-authorized “therapeutic containment.”
- Parents later discovered repeated restraints had occurred without timely notification and sought an administrative hearing under the IDEA in 2010, resulting in a 2011 settlement decision by the Office of Administrative Hearings.
- In December 2016, over five years after administrative exhaustion, plaintiff sued Institutional Defendants under the ADA and § 504 and sued Individual Defendants under 42 U.S.C. § 1983 for Fourth and Fourteenth Amendment violations.
- Defendants moved to dismiss: (1) Individual Defendants argued § 1983 claims lacked particularized factual allegations tying each defendant to constitutional deprivations; (2) Institutional Defendants argued ADA and § 504 claims were time-barred and that California minority tolling should not apply.
- The Court granted dismissal: § 1983 claims against Individual Defendants dismissed without prejudice for failure to plead specific acts by each defendant; ADA and § 504 claims dismissed with prejudice as barred by the applicable statute of limitations because California minor tolling does not apply to these education-related claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of § 1983 pleading against Individual Defendants | Complaint’s allegations of 112+ restraint episodes make it plausible some named individuals were involved; detailed repetition unnecessary | Complaint fails to allege specific facts showing each individual defendant’s own unconstitutional conduct; group pleading insufficient | Dismissed without prejudice — plaintiff must plead specific facts tying each individual to constitutional violations |
| Availability of California minor tolling to ADA and § 504 claims | Minor tolling should apply; claims seek compensatory relief and thus tolling is appropriate | Minor tolling is inconsistent with federal policy requiring prompt assertion of education-related claims; parents could have filed earlier | Dismissed with prejudice — minor tolling inapplicable under Ninth Circuit precedent (Alexopulos) |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must state a plausible claim for relief)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (legal conclusions not entitled to assumption of truth in pleading)
- Alexopulos v. San Francisco Unified School District, 817 F.2d 551 (9th Cir. 1987) (California minor tolling inapplicable to education-related claims because it undermines prompt enforcement policy)
- Starr v. Baca, 652 F.3d 1202 (9th Cir. 2011) (individual § 1983 liability requires pleading each official’s own actions)