2:23-cv-12817
E.D. Mich.May 22, 2025Background
- Three parents sued Hamtramck Public Schools and the Michigan Department of Education, alleging their disabled children were denied essential special education services.
- The parents claimed their children (with autism or Down syndrome) received inadequate support, such as shortened school days, lack of assigned aides, or refusals to evaluate for additional services.
- State-level complaints resulted in findings that the school district violated students’ rights, with corrective plans issued, but parents alleged ongoing deficiencies and lack of state enforcement.
- The parents brought a federal class action seeking damages under the ADA and Rehabilitation Act and injunctive relief under IDEA, ADA, and Rehabilitation Act.
- The State moved to dismiss, citing sovereign immunity to ADA claims; the district court denied the motion, and this interlocutory appeal followed.
- The Sixth Circuit reversed, holding that Title II of the ADA does not impose liability on the State for the actions of independent school districts in Michigan.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| State Liability Under ADA Title II | State liable for ADA violations by school districts it funds/supervises | State not liable for independent districts’ conduct; no ADA supervisory liability | No ADA claim stated against the State; liability limited to districts |
| Sovereign Immunity & ADA | ADA abrogates state immunity for discrimination in public education | Sovereign immunity not abrogated because there’s no direct ADA violation by the State | State immune from suit as no ADA violation alleged against it |
| Supervisory Liability in Education Laws | State’s supervision/funding means it can be sued for district’s violations | Statute does not support supervisory liability for state over districts | ADA does not impose supervisory liability on Michigan |
| IDEA Crossover with ADA | IDEA’s requirements mean State’s general oversight should support ADA liability | IDEA oversight does not transform local operation into State’s ADA responsibility | IDEA’s provisions do not provide basis for ADA claim against State |
Key Cases Cited
- City of Boerne v. Flores, 521 U.S. 507 (prophylactic legislation under the Fourteenth Amendment requires congruence and proportionality)
- Tennessee v. Lane, 541 U.S. 509 (Title II ADA claims evaluated on a claim-by-claim basis for sovereign immunity)
- United States v. Georgia, 546 U.S. 151 (articulates three-step test to determine when ADA abrogates state sovereign immunity)
- Mt. Healthy City Sch. Dist. Bd. of Educ. v. Doyle, 429 U.S. 274 (school districts are independent entities, not arms of the State, for immunity purposes)
- Alden v. Maine, 527 U.S. 706 (states retain sovereign immunity unless validly abrogated)
- Fitzpatrick v. Bitzer, 427 U.S. 445 (Congress may abrogate sovereign immunity using enforcement powers under Fourteenth Amendment)