Brian Betz v. Abbe Satteson, 17-1950

Incident at Shikellamy Middle School (Feb 2014): 7th-grader I.B. attempted to exit after final bell; teacher Abbe Satteson blocked the door while stopping another student for scooter rule violation.
I.B. ducked to pass under Satteson’s arm, collided with her elbow/torso, struck the door, and sustained a head laceration requiring nine staples.
Parents (Brian and Deborah Betz) sued Satteson and others in federal court asserting substantive due process and Pennsylvania torts (assault, battery, intentional infliction of emotional distress).
Defendants moved for summary judgment; the District Court ordered and reviewed surveillance video and granted summary judgment for defendants; Plaintiffs appealed only Satteson-related substantive due process and assault/battery rulings.
Third Circuit reviewed de novo; it affirmed summary judgment because plaintiffs failed to raise a genuine dispute that Satteson acted with the malicious, sadistic intent required for a constitutional violation or the intent to cause harmful/offensive contact required for assault/battery.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether teacher’s conduct violated substantive due process ("conscience-shocking" / excessive force in schools)	Satteson intentionally contacted and injured I.B.; that contact and injury satisfy Gottlieb factors and show malice	Contact was at most blocking a door to prevent exit; no evidence of malicious or sadistic intent to harm	Affirmed — no genuine dispute that Satteson acted maliciously/sadistically; no constitutional violation
Whether evidence (including surveillance video) created triable issues of fact	Video and witness testimony show Satteson shoved/hit I.B.; District Court mischaracterized video and improperly weighed evidence	Video and other evidence are consistent with blocking the door; plaintiff’s own testimony says he ducked under an arm	Affirmed — record even viewed favorably to plaintiff insufficient to create material factual dispute
Whether Satteson committed Pennsylvania assault	I.B. was intentionally struck; assault requires attempt/intent to cause harm or offensive contact	Any contact was incidental to blocking an exit, lacking intent to cause harm	Affirmed — plaintiffs failed to show intent to cause harmful/offensive contact
Whether Satteson committed Pennsylvania battery	Physical contact occurred and caused injury	Contact lacked requisite intent to harm; was defensive/disciplinary	Affirmed — insufficient evidence of intent to cause harm for battery

Gottlieb ex rel. Calabria v. Laurel Highlands Sch. Dist., 272 F.3d 168 (3d Cir. 2001) (four-part test for excessive force in schools; malicious and sadistic intent dispositive)
County of Sacramento v. Lewis, 523 U.S. 833 (1998) (substantive due process requires conduct that is arbitrary or conscience-shocking)
Metzger ex rel. Metzger v. Osbeck, 841 F.2d 518 (3d Cir. 1988) (teacher’s choke-like restraint could support malicious-intent finding)
Renk v. City of Pittsburgh, 641 A.2d 289 (Pa. 1994) (assault and battery elements require intent to cause harmful or offensive contact)
Anderson v. Liberty Lobby, 447 U.S. 242 (1986) (summary judgment standard; genuine dispute if reasonable jury could return verdict for nonmoving party)