H. v. SCHUYLKILL VALLEY SCHOOL DISTRICT
5:12-cv-05925
| E.D. Pa. | Feb 20, 2014Background
- Plaintiffs sue Schuylkill Valley School District and officials on behalf of minor Anders Hemdal after a four-day suspension for consensual sexual conduct on a school trip to Morocco.
- Amended complaint alleging federal due process and equal protection violations, and state-law claims (intentional infliction, defamation, privacy invasion).
- Defendants moved to dismiss under Fed. R. Civ. P. 12(b)(6) for failure to state a claim.
- Court applies Twombly/Iqbal plausibility standard and determines federal due process requirements are satisfied by the informal, timely notice and meetings.
- Court dismisses federal claims with prejudice, declines supplemental jurisdiction over state-law claims, and dismisses state-law claims without prejudice; no amendment deemed futile.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether due process was violated under the Fourteenth Amendment | Hemdal argues due process denied due to PA code procedures. | Defendants contend federal due process is satisfied; state-law procedures not controlling. | No due process violation; proper notice and informal discussions sufficed. |
| Whether equal protection was violated (conspiracy claim) | Plaintiffs claim a conspiracy to deny equal protection. | Plaintiffs fail to allege purposeful discrimination or injury. | Equal protection claim dismissed for lack of plausible facts. |
| Whether federal claims can proceed given state-law based procedures | Alleged due process violation based on state statute. | Federal law governs due process; state procedures do not define federal rights. | Dismissed federal claims; state-law claims may proceed in state court if pursued. |
| Whether the court should exercise supplemental jurisdiction over state-law claims | N/A | N/A | Declined; no viable federal claim to support supplemental jurisdiction. |
| Whether amendment to cure the defects would be futile | Plaintiffs would amend to state federal rights. | Amendment would not alter lack of viable federal claim. | Amendment would be futile; dismissal with prejudice of federal claims and dismissal of state claims without prejudice. |
Key Cases Cited
- Goss v. Lopez, 419 U.S. 565 (U.S. 1975) (due process standards for student suspensions; notice and opportunity to be heard)
- Shuman ex rel. Shertzer v. Penn Manor School Dist., 422 F.3d 141 (3d Cir. 2005) (state law does not define federal due process in this context)
- Lake v. Arnold, 112 F.3d 682 (3d Cir. 1997) (equal protection requirements; must show purposeful discrimination)
- Palmer by Palmer v. Merluzzi, 868 F.2d 90 (3d Cir. 1989) (elements of equal protection claim; burden on plaintiff)
- Huebschen v. Dep’t of Health and Social Servs., 716 F.2d 1167 (7th Cir. 1983) (necessity of showing class-based discrimination for equal protection)
- Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343 (1988) (when federal claims are dismissed, court may decline supplemental jurisdiction)
- Goss v. Lopez, 419 U.S. 565 (U.S. 1975) (due process required in public school suspensions)