Heyne v. Metropolitan Nashville Public Schools
655 F.3d 556
| 6th Cir. | 2011Background
- Heyne, a White Hillsboro High School senior and football player, was ten-daysuspended after an incident with an African-American student, D.A., in the parking lot.
- Manuel, Hillsboro’s principal, allegedly instructed staff to be lenient with African-American students and later admitted suspending Heyne to “cover” Hillsboro against liability.
- Heyne received an initial two-day suspension for reckless endangerment, then two additional charges led to a ten-day suspension and referral to the Disciplinary Hearing Board.
- Heyne’s pre-hearing materials were not shared with the board, he was not allowed to present witnesses, and the hearing was closed to him, his parents, and his attorney.
- Chambers(Its Director/appeals official) denied an affidavit and ultimately denied Heyne’s appeal; the MNPS Board of Public Education declined a hearing and affirmed the suspension.
- Heyne sued under 42 U.S.C. § 1983 alleging procedural due process and equal protection violations; district court dismissed some claims; appellate review addresses qualified immunity and §1983 claims against individual and metropolitan defendants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Heyne plausibly alleges bias tainted due process | Heyne claims Manuel’s bias compromised impartiality | Manuel argues no improper bias; standard pleading suffices | Yes; Manuel plausibly biased, impugning due process rights |
| Whether Perry and Jones violated due process via directives to suspend | Heyne asserts Perry and Jones participated and biased the outcome | No per se due process violation; role unclear | Yes; plausible claim against Perry and Jones for procedural due process |
| Whether Chambers and Thompson violated due process on appeal | Heyne alleges post-hearing participation affected due process | Appeals by officials post-suspension do not implicate due process | No; Heyne failed to state §1983 claim against Chambers and Thompson |
| Whether Heyne’s equal protection claim is plausibly race-based | Heyne alleges harsher discipline due to race; Manuel aware of race statistics | Discipline decisions not shown to be race-based | Yes against Manuel, Perry, Jones; Chambers and Thompson dismissed for equal protection |
Key Cases Cited
- Goss v. Lopez, 419 U.S. 565 (1975) (due process in 10-day suspensions requires minimal safeguards)
- Newsome v. Batavia Local Sch. Dist., 842 F.2d 920 (6th Cir.1988) (bias can require disqualification of decisionmaker)
- Laney v. Farley, 501 F.3d 577 (6th Cir.2007) (due process in school discipline; separation of roles wary of bias)
- Spadafore v. Gardner, 330 F.3d 849 (6th Cir.2003) (conspiracy claims require specific pleading and plan)
- Lamb v. Panhandle Cmty. Unit Sch. Dist. No. 2, 826 F.2d 526 (7th Cir.1987) (role of initiator may not violate due process if impartiality maintained)
- Mettetal v. Vanderbilt Univ., Legal Dep't, 147 Fed.Appx. 577 (6th Cir.2005) (conspiracy pleading requirements; single plan not shown)