Barbara Wyatt v. Rhonda Fletcher
2013 U.S. App. LEXIS 11045
| 5th Cir. | 2013Background
- Wyatt, as next-friend of S.W., sued two Kilgore HS softball coaches under §1983 for violating S.W.’s privacy (Fourteenth) and alleging a Fourth Amendment seizure claim.
- Coaches allegedly disclosed S.W.’s sexual orientation to Wyatt in a meeting; this disclosure is central to the Fourteenth Amendment claim.
- Locker-room meeting with S.W. allegedly involved confinement, shouting, and coercive questioning; a related Fourth Amendment claim was asserted.
- District court denied qualified immunity to Fletcher and Newell; the magistrate found disputed facts precluded summary judgment.
- Fifth Circuit reversed, holding no clearly established Fourteenth Amendment privacy right or Fourth Amendment right applicable to school context, thus granting qualified immunity to the coaches.
- Decision remanded for entry of judgment dismissing federal claims against the individual defendants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a student’s Fourteenth Amendment privacy right is clearly established. | Wyatt asserts a clearly established privacy right in sexual orientation. | Wyatt has no clearly established right; disclosures to a parent do not violate a clearly established privacy right. | No clearly established right; qualified immunity applies. |
| Whether a student’s Fourth Amendment rights apply to locker-room confrontation. | Wyatt contends the locker-room confrontation violated the Fourth Amendment. | Locker-room privacy in schools is diminished; actions reasonable under context. | No clearly established Fourth Amendment right; qualified immunity applies. |
| Whether the district court erred in denying qualified immunity given the above rights. | District court correctly denied immunity due to disputed facts and rights. | No clearly established law; officials acted reasonably. | District court erred; coaches entitled to qualified immunity. |
| What is the governing standard for clearly established law in qualified immunity here? | Precedent supports a private right to confidentiality in school context. | High bar; no controlling authority clearly establishing such a right in this context. | Standard requires a clearly established, particularized right; not met. |
Key Cases Cited
- Vernonia School District 47J v. Acton, 515 F.3d 646 (U.S. 1995) (reduced privacy expectations for student athletes; locker rooms not highly private)
- Griswold v. Connecticut, 381 U.S. 479 (U.S. 1965) (privacy of personal matters under privacy right source)
- Whalen v. Roe, 429 U.S. 589 (U.S. 1977) (individual interest in avoiding disclosure of personal matters)
- Sterling v. Borough of Minersville, 232 F.3d 190 (3d Cir. 2000) (privacy right in sexual orientation discussed outside school context)
- Fadjo v. Coon, 633 F.2d 1172 (5th Cir. 1981) (privacy disclosure in other contexts; not controlling here)
- ACLU of Miss., Inc. v. Mississippi, 911 F.2d 1066 (5th Cir. 1990) (privacy vs. public disclosure balancing considerations)