C.G. v. Redding Christian School
2:19-cv-00348
E.D. Cal.Mar 17, 2020Background
- Minor plaintiff C.G., diagnosed with ADHD, attended Redding Christian School from kindergarten through second grade and allegedly exhibited behavior related to his disability; his parents informed teachers and requested accommodations/supervision.
- During 2016–17 C.G. made inappropriate sexual remarks; he was removed from after‑school care in Feb 2017 and expelled by Redding Christian in May 2017 for alleged multi‑month sexual misconduct with other students.
- Plaintiffs (C.G. and his parents) sued under Section 504 of the Rehabilitation Act (29 U.S.C. § 794), alleging disability discrimination and seeking relief in federal court; they also asserted several state‑law claims.
- Redding Christian moved to dismiss under Fed. R. Civ. P. 12(b)(1), arguing it is not a recipient of federal financial assistance because the National School Lunch/Breakfast federal contract is held by Shasta Union High School District, which prepares and delivers meals.
- The court analyzed whether Redding Christian received federal funding for Rehabilitation Act purposes and applied U.S. Dep’t of Transp. v. Paralyzed Veterans of Am., concluding that merely benefiting from a recipient’s federally funded program does not make an entity a recipient.
- The court granted the motion to dismiss for lack of subject‑matter jurisdiction as to the Section 504 claim, denied further leave to amend that federal claim as futile, declined supplemental jurisdiction over state claims, and dismissed those state claims without prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Redding Christian is a "recipient of federal financial assistance" under Section 504 because its students receive meals under the National School Lunch/Breakfast Programs | Redding Christian receives federal funding through the Programs because its students are provided federally funded meals | Shasta Union holds the federal contract and receives the funds; Redding Christian only benefits from Shasta Union’s service and does not receive federal assistance itself | Court: Redding Christian is not a federal funding recipient; benefit too attenuated under Paralyzed Veterans; no Rehab Act jurisdiction |
| Whether to grant leave to amend the Section 504 claim and whether federal court should exercise supplemental jurisdiction over state claims | Plaintiffs sought relief in federal court and had asked (alternatively) for judgment on the pleadings or leave to pursue claims | Defendant argued lack of federal jurisdiction and dismissal | Court: Leave to amend the federal Section 504 claim denied as futile; declined supplemental jurisdiction over state claims; state claims dismissed without prejudice |
Key Cases Cited
- U.S. Dep’t of Transp. v. Paralyzed Veterans of Am., 477 U.S. 597 (Supreme Court 1986) (distinguishes recipients of federal assistance from entities that merely benefit; controls scope of § 504 coverage)
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (Supreme Court 1994) (federal courts are courts of limited jurisdiction; party asserting jurisdiction bears the burden)
- Arbaugh v. Y & H Corp., 546 U.S. 500 (Supreme Court 2006) (limitations on subject‑matter jurisdiction cannot be forfeited or waived)
- Foman v. Davis, 371 U.S. 178 (Supreme Court 1962) (standards governing leave to amend pleadings)