Crochran ex rel. Shields v. Columbus City Schools, 278 F. Supp. 3d 1013

Background

N.C., a fifth-grade student with autism and ADHD, attended a special-education class at South Mifflin STEM Academy taught by Courtney Plummer.
On Feb. 20, 2013, after N.C. became disruptive, a co-teacher suggested using a school-owned “body sox” (a breathable lycra sensory garment) to calm him.
Plummer asked N.C. if he wanted to wear the body sox; he stepped in himself while Plummer held it open; the garment’s head opening is secured by velcro and the arms are not restrained.
While wearing the body sox, N.C. fell a few seconds later, struck his face on the floor, and received first aid; he described enjoying the garment before the fall.
Plaintiffs sued under 42 U.S.C. § 1983 (Fourth and Fourteenth Amendments), IDEA, the ADA, Section 504, and various Ohio state tort claims; defendants moved for summary judgment.
The district court granted summary judgment for defendants on the federal constitutional, IDEA, ADA, and § 504 claims, and declined supplemental jurisdiction over state-law claims, dismissing them without prejudice.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
§1983 — Equal Protection	Pls: Plummer singled out N.C. by using the body sox when she hadn’t used it on others.	Ds: Body sox were a therapeutic tool used for autistic students; use was rationally related to legitimate educational purposes.	Granted for Ds — no evidence of disparate treatment without rational basis.
§1983 — Substantive Due Process	Pls: Use of body sox was punitive, covered face, and risked harm — shocks the conscience.	Ds: Use was pedagogical, nonviolent, recommended by staff, and N.C. put it on himself; facts at most suggest negligence.	Granted for Ds — conduct did not "shock the conscience."
§1983 — Fourth Amendment	Pls: Body sox amounted to an unlawful seizure/restraint.	Ds: The garment did not meaningfully restrict movement; even if a seizure, it was justified and reasonable to restore order.	Granted for Ds — no seizure; alternatively, seizure was reasonable if one occurred.
IDEA Exhaustion	Pls: Plaintiffs seek money damages for physical injury and argue IDEA exhaustion is futile/ unnecessary.	Ds: Federal scheme requires exhaustion for claims arising under IDEA.	Court: §1983 claims do not arise under IDEA so exhaustion not required; IDEA claim dismissed (no viable IDEA claim).
ADA / §504 Discrimination	Pls: Use of body sox discriminated on basis of disability and resulted in injury.	Ds: Use was a therapeutic accommodation, not in bad faith or gross misjudgment; nothing showing discriminatory intent or gross error.	Granted for Ds — no evidence of bad faith or gross misjudgment; discrimination claim fails.
State-law torts & supplemental jurisdiction	Pls: State claims (assault, battery, negligence, etc.) remain.	Ds: Federal claims disposed; federal court should decline supplemental jurisdiction.	Court declined supplemental jurisdiction and dismissed state claims without prejudice.

Key Cases Cited

Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standards)
Anderson v. Liberty Lobby, 477 U.S. 242 (genuine issue for trial standard)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (assessing sufficiency of evidence at summary judgment)
Gohl v. Livonia Pub. Sch., 836 F.3d 672 (6th Cir. 2016) (substantive due process school-context standard)
Domingo v. Kowalski, 810 F.3d 403 (6th Cir. 2015) ("shock the conscience" framework for educator conduct)
Couture v. Bd. of Educ. of the Albuquerque Pub. Schs., 535 F.3d 1243 (10th Cir. 2008) (reasonableness of disciplinary measures in special-education setting)
New Jersey v. T.L.O., 469 U.S. 325 (Fourth Amendment in schools)
Vernonia Sch. Dist. 47J v. Acton, 515 U.S. 646 (student liberty and school context)
F.H. v. Memphis City Sch., 764 F.3d 638 (6th Cir. 2014) (distinguishing educational vs non-educational injuries re: IDEA exhaustion)
S.S. v. E. Ky. Univ., 532 F.3d 445 (ADA/§504 analysis in education context)