Cynthia Yates v. Cobb County School District
687 F. App'x 866
| 11th Cir. | 2017Background
- At a high-school evening advisement event, parent Cynthia Yates loudly complained about the event and said repeatedly, “whoever organized this needs to be shot in the head,” directed at faculty organizer Gillian Moody. Staff reported Yates was yelling and pounding a table.
- The principal asked school resource officer Charles Rogers to investigate; Rogers collected written witness statements and spoke with witnesses, then sought an arrest warrant under Georgia’s school-disruption statute. A magistrate found probable cause and a warrant issued; the charge was later nolle prossed after Yates agreed to apologize and undergo anger management.
- Months later an assistant principal (O’Neill), mistakenly believing a trespass "warrant" existed, told Yates by phone that she was prohibited from entering school property and warned she would be arrested if she returned; no written criminal trespass warning was ever issued by CCSD police.
- Yates sued pro se under 42 U.S.C. § 1983 alleging First Amendment retaliation, Fourth Amendment false arrest, Fourteenth Amendment due process and voting-rights claims, and a Monell claim against Cobb County School District (CCSD). She sought damages, not injunctive relief.
- The district court granted summary judgment for defendants; the Eleventh Circuit affirmed, rejecting Yates’s discovery challenge, holding individual defendants entitled to qualified immunity, finding arguable probable cause for the warrant, and rejecting Yates’s Monell and due-process theories against CCSD.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Denial of motion to compel discovery | Yates argued district court abused discretion by denying her motion to compel. | Defendants argued motion was untimely and exceeded page limits. | Denial affirmed: motion was filed late and exceeded local page limits; pro se status does not excuse noncompliance. |
| First Amendment retaliation | Yates contended her speech (parent complaints at school event) was protected and defendants retaliated. | Defendants argued no clearly established law forbade restricting a parent’s private speech at a school event in these circumstances. | Claim dismissed on qualified immunity ground: no clearly established First Amendment right on these facts. |
| Fourth Amendment false arrest (Officer Rogers) | Yates argued witness statements were false and Rogers’ warrant affidavit was misleading. | Rogers argued he had arguable probable cause based on multiple consistent witness statements and his own interviews. | Rogers entitled to qualified immunity: reasonable officer could have believed probable cause existed; no showing Rogers recklessly or knowingly included false statements. |
| Monell / Fourteenth Amendment due process (CCSD) | Yates argued CCSD policy or failure to train caused deprivation (trespass warning/no notice). | CCSD argued no written trespass warning was issued; O’Neill lacked final policymaking authority and was misinformed; no pattern or obvious training need shown. | Summary judgment for CCSD affirmed: no policy/custom or deliberate indifference shown; single mistaken communication insufficient for Monell liability. |
Key Cases Cited
- Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (municipal liability requires policy or custom)
- Hazelwood Sch. Dist. v. Kuhlmeier, 484 U.S. 260 (school regulation of school-sponsored student speech)
- Tinker v. Des Moines Indep. Cmty. Sch. Dist., 393 U.S. 503 (student private speech protection standard on campus)
- Boim v. Fulton Cty. Sch. Dist., 494 F.3d 978 (school may restrict private speech reasonably perceived as threat)
- Jane Doe I v. Valencia Coll. Bd. of Trs., 838 F.3d 1207 (distinguishing school-sponsored vs. private speech)
- Malley v. Briggs, 475 U.S. 335 (qualified immunity for officers who request warrants unless affidavit plainly lacks probable cause)
- Hope v. Pelzer, 536 U.S. 730 (clearly established law and fair warning standard)
- Vinyard v. Wilson, 311 F.3d 1340 (qualified immunity/fair warning analysis)
- Grider v. City of Auburn, 618 F.3d 1240 (two-prong qualified immunity framework)
- Coffin v. Brandau, 642 F.3d 999 (context-specific fair-warning inquiry)
- Doe v. Sch. Bd. of Broward Cty., 604 F.3d 1248 (municipal liability and final policymaker analysis)
- Craig v. Floyd Cty., 643 F.3d 1306 (custom requires longstanding, widespread practice)
- Gold v. City of Miami, 151 F.3d 1346 (failure-to-train requires obvious need for training)