Christy v. McCalla
79 So. 3d 293
La.2011Background
- Justin Christy, a high school senior, was accused of possessing alcohol after a whiskey bottle was found in his backpack and later broke in a classroom.
- Andrew Heacock confessed to placing the bottle in Christy’s backpack, but Christy claimed he did not know it was there.
- An informal hearing recommended expulsion; a preliminary appeals hearing reduced the duration of the expulsion but maintained the penalty.
- The full School Board held an executive-session hearing on November 18, 2003, after which Christy was expelled by a 9–2 vote.
- Christy and his mother sued the School Board, alleging due process violations and other damages; the district court awarded $50,000.
- The court of appeal affirmed liability and damages; the supreme court granted review to address due-process and damages tied to expulsion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Christy was denied due process at any stage | Christy asserts due process was denied, tainting the expulsion | Board argues due process was provided through a full hearing | No proven denial of due process; Board afforded opportunity to be heard |
| Whether causation supports tort damages for wrongful discipline | Evidence shows negligent handling and failure to consider exculpatory testimony | Disciplinary process culminated in a Board decision; causation not shown by Board’s actions | Causation not established for Board’s liability under the record presented |
| Whether the sanction violated La. R.S. 17:416 and due-process framework | Expulsion exceeded statutory authority or due-process safeguards | Statute allows expulsion after suspension; record does not show violation | Discipline did not violate the statute; no due-process violation proven |
Key Cases Cited
- Goss v. Lopez, 419 U.S. 565 (U.S. 1975) (due process in school suspensions; liberty interest at stake)
- Swindle v. Livingston Parish Sch. Bd., 655 F.3d 386 (5th Cir. 2011) (state owes minimal due-process protections; damages may be available under constitutional framework)
- Pinsonneault v. Merchants & Farmers Bank & Trust Co., 816 So.2d 270 (La. 2002) (five elements of the duty-risk analysis for tort liability in Louisiana)