Jackson v. Indian Prairie School District 204
653 F.3d 647
7th Cir.2011Background
- Paula Jackson was a tenured special education support teacher for Indian Prairie School District 204.
- W.K. was a second/third/fourth grade autistic student with frequent violent outbursts in the White Eagle school.
- Despite recommendations, W.K. often remained in general education settings rather than being transferred to an alternative school.
- Jackson was injured when W.K. aggressive outburst required intervention and she was asked to discuss with him upstairs.
- IEP meetings repeatedly noted W.K.’s violent episodes and ongoing need for highly structured support, with debates about placement between general education and alternative settings.
- District officials ultimately allowed W.K. to remain at White Eagle prior to a March 13, 2008 incident that caused Jackson’s injuries.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district actions created or increased danger to Jackson | Jackson | Jackson’s claim fails under endangerment vs. protection distinction | Not met; actions did not shock conscience |
| Whether district’s decision not to transfer W.K. shocks conscience | Jackson argues deliberate indifference | Decision was flawed but not conscience-shocking | No conscience-shocking conduct; district not liable |
| Whether state-created danger requires greater proof beyond flawed decisions | State created/increased danger to Jackson | Actions not enough to shock conscience | Not established under the standard |
Key Cases Cited
- London v. RBS Citizens, N.A., 600 F.3d 742 (7th Cir.2010) (pleading standard for §1983 claims against state actors)
- County of Sacramento v. Lewis, 523 U.S. 833 (Supreme Court 1998) (shock the conscience requires egregious conduct)
- King ex rel. King v. East St. Louis School Dist., 496 F.3d 812 (7th Cir.2007) (deliberate indifference required for conscience-shocking conduct)
- DeShaney v. Winnebago County Dep't of Social Services, 489 U.S. 189 (Supreme Court 1989) (state has no duty to protect individuals from private harm unless in custody; but exceptions apply)
- White v. Rochford, 592 F.2d 381 (7th Cir.1979) (summary judgment reversal when government action left risk to children)
- Reed v. Gardner, 986 F.2d 1122 (7th Cir.1993) (reversal where officers’ conduct created risk to others)
- Monfils v. Taylor, 165 F.3d 511 (7th Cir.1998) (evidentiary standards for conscience-shocking analysis)
- Walker v. Sheahan, 526 F.3d 973 (7th Cir.2008) (summary judgment standard and due process evaluation)