Jahn v. Farnsworth
2014 U.S. Dist. LEXIS 96426
| E.D. Mich. | 2014Background
- High-school senior Steven Jacob "Jake" Jahn was confronted March 19, 2012 about a stolen teacher laptop, admitted taking it, and the laptop was recovered from his home.
- Principal Farnsworth and assistant principal Valko informed Jake he faced a 10-day suspension and a recommendation for long-term suspension; Jake was released to his father after the meeting.
- Several hours later Jake left home without others' knowledge and died by suicide in a single-vehicle crash that evening.
- Plaintiff (Jake’s father/personal representative) sued under 42 U.S.C. § 1983 for violations of procedural and substantive due process (state-law claims were dismissed earlier).
- The district court considered whether (1) Jake received constitutionally adequate process and (2) defendants created the danger of suicide under the state-created-danger theory; defendants also raised qualified immunity and municipal liability defenses.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Procedural due process — adequacy of hearing for suspension/long-term suspension | Jake was effectively suspended for remainder of year without formal pre-expulsion hearing or being shown the video evidence, depriving him of due process | Administrators provided oral notice of charges, explained evidence, allowed Jake to tell his side (Goss minimum); any long-term recommendation had not been finalized and appeal procedures existed | Court: No procedural due process violation — Goss-level procedures were followed; admission of guilt and recovery of laptop undercut any prejudice; speculative appeals insufficient |
| Procedural due process — right to view evidence | Failure to show video to Jake violated Newsome-type protections | Only explanation of evidence is required under Goss; administrators explained the evidence and Jake confessed | Court: No violation — explanation (not viewing) satisfied due process; Newsome inapposite because no undisclosed evidence after hearing |
| Substantive due process — state-created-danger (suicide) | Statements and actions (threats to notify police/colleges, allowing him to leave) created or increased risk of suicide and officials knew or should have known | Sixth Circuit has not recognized liability for suicide under state-created-danger; no evidence defendants knew Jake was suicidal; parents were notified and took custody | Court: No substantive due process violation — Sixth Circuit reluctant to find state-created-danger liability for suicides; here defendants lacked knowledge of suicidal risk and did not create the danger |
| Qualified immunity & municipal liability | Rights violated so officials and district liable | Officials entitled to qualified immunity (no clearly established right to formal hearing for long suspension; no established right to be protected from suicide in these circumstances); district policies complied with law | Court: Qualified immunity for individual defendants; Marysville Public Schools not liable (no unconstitutional policy/custom shown) |
Key Cases Cited
- Goss v. Lopez, 419 U.S. 565 (U.S. 1975) (students facing short suspension entitled to oral/written notice, explanation of evidence, and chance to present their side)
- Newsome v. Batavia Local Sch. Dist., 842 F.2d 920 (6th Cir. 1988) (Goss sets minimum procedures for expulsion; pre-expulsion hearing before impartial trier required for expulsion)
- DeShaney v. Winnebago County Dept. of Social Servs., 489 U.S. 189 (U.S. 1989) (state generally not liable for failure to protect from private violence absent special custody or state-created-danger exception)
- County of Sacramento v. Lewis, 523 U.S. 833 (U.S. 1998) (substantive due process violation requires conscience-shocking conduct)
- Armijo v. Wagon Mound Pub. Schs., 159 F.3d 1253 (10th Cir. 1998) (school officials who knowingly sent suicidal, at-risk student home without parental notice could create danger)
- Sloane v. Kanawha County Sheriff Dep’t, 342 F. Supp. 2d 545 (S.D. W. Va. 2004) (repeated interrogation of minor despite concern about suicidal risk supported state-created-danger theory)
- Kerns v. Independent Sch. Dist. No. 31 of Ottawa Cnty., 984 F. Supp. 2d 1144 (N.D. Okla. 2013) (allegations that school sent intoxicated, extremely upset minor home and he subsequently died survived early dismissal)
- Cutlip v. City of Toledo, [citation="488 F. App'x 107"] (6th Cir. 2012) (Sixth Circuit has not found state-created-danger liability for suicide; courts reluctant to hold state liable when victim commits suicide)
- Lowery v. Enyart, 497 F.3d 584 (6th Cir. 2007) (federal courts should not second-guess routine school-administrator disciplinary judgments)