Doe v. Detroit Public Schools Community District
2:21-cv-11136
E.D. Mich.Mar 31, 2022Background
- May 2, 2018 incident at Brewer Academy: then-7-year-old second grader C.F. Doe (with IEP and developmental disabilities) was sent to guidance counselor Sammie Edwards for behavioral issues and was humiliated in a seventh-grade classroom while students mocked him; an on-site video captures the episode.
- Edwards waved a ruler, belittled Doe, ordered him to stand, permitted/encouraged student taunting, seized a student’s cellphone recording, and later escorted the recording students to an administrator; the incident lasted under 90 seconds on video.
- Edwards had prior disciplinary history with DPSCD and a 2003 criminal child-abuse conviction; DPSCD later charged and terminated her employment and prosecutors charged her with fourth-degree child abuse.
- Plaintiff (by next friend Mother of C.F. Doe) sued in state court asserting: (1) § 1983 substantive due process claim against Edwards; (2) Monell municipal/supervisory liability against Detroit Public Schools Community District (DPSCD); and state-law claims (gross negligence, assault, IIED) and a PWDCRA claim against Edwards and DPSCD.
- DPSCD moved for judgment on the pleadings under Rule 12(c); it submitted the incident video. The court treated facts in the complaint (and the video) as true for purposes of the motion.
- Ruling: the court dismissed Counts I and II (§ 1983 claims) with prejudice and declined supplemental jurisdiction over the remaining state-law claims (Counts III–VI), remanding the case to Wayne County Circuit Court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Edwards' conduct violated substantive due process (conscience-shocking) | Edwards' humiliation and bullying of a vulnerable seven‑year‑old caused severe psychological injury and shocks the conscience | Conduct was non-physical, brief, and not so brutal or malicious as to constitute a constitutional violation | Dismissed: verbal/non-physical harassment here did not meet the conscience‑shocking standard |
| Whether DPSCD is liable under Monell for Edwards' alleged constitutional violation | DPSCD failed to train/supervise Edwards despite prior misconduct, creating municipal liability | DPSCD argued no underlying constitutional violation and thus no Monell liability | Dismissed: Monell claim fails because no actionable § 1983 violation was shown |
| Whether plaintiff was entitled to Rule 56(d) discovery before ruling on DPSCD's motion | Plaintiff sought discovery about Edwards' prior misconduct and DPSCD practices to support Monell and substantive‑due‑process claims | DPSCD noted the motion was under Rule 12(c) and no outside evidence was required or submitted to convert it to summary judgment | Denied: discovery under Rule 56(d) not applicable to a Rule 12(c) motion; plaintiff must plead a plausible claim without discovery |
| Whether the federal court should retain supplemental jurisdiction over state-law claims | Plaintiff wanted federal adjudication of state claims alongside dismissed federal claims | DPSCD sought dismissal of federal counts; no special insistence on federal resolution of state claims | Court declined supplemental jurisdiction and remanded state claims to state court |
Key Cases Cited
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must contain enough factual matter to state a plausible claim)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (legal conclusions not entitled to assumed truth for pleading analysis)
- County of Sacramento v. Lewis, 523 U.S. 833 (1998) (due‑process "conscience‑shocking" standard)
- Domingo v. Kowalski, 810 F.3d 403 (6th Cir. 2016) (framework for evaluating school employees' use of force and intent)
- Gohl v. Livonia Pub. Schs., 836 F.3d 672 (6th Cir. 2016) (bullying/harassment can, in some contexts, constitute conscience‑shocking conduct)
- Bailey v. City of Ann Arbor, 860 F.3d 382 (6th Cir. 2017) (courts may consider video evidence on a motion to dismiss when it captures the incident)
- Monell v. Dep’t of Social Servs., 436 U.S. 658 (1978) (municipal liability requires underlying constitutional violation and a policy/custom causation link)
- Carnegie‑Mellon Univ. v. Cohill, 484 U.S. 343 (1988) (district courts have discretion to decline supplemental jurisdiction over state‑law claims)