Knight v. Minneapolis Public Schools
0:25-cv-00417
D. MinnesotaApr 14, 2025Background
- Desiree Knight, acting as legal guardian for her minor daughter A.G., alleges violations against Minneapolis Public Schools related to A.G.'s education and accommodations for disabilities.
- Knight claims A.G., who receives special education services, was improperly restrained, denied timely education services, and did not receive required specialized transportation.
- Knight filed the lawsuit pro se, seeking damages for both herself (from alleged time and resource losses) and on behalf of A.G. for ADA violations.
- Defendant moved to dismiss the case, arguing lack of proper party representation and insufficient factual allegations.
- The court reviewed whether Knight had standing to bring the ADA claims and whether her pleadings stated a viable claim.
- The court dismissed the case without prejudice, allowing Knight the option to refile with legal representation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Pro se representation of minor | Knight can sue as A.G.’s guardian | Non-attorney parents cannot represent minors | Court: Parent cannot represent minor pro se |
| ADA claim for parent (Knight) | Entitled to damages for her losses from ADA violations | ADA claims are for disabled individuals only | Court: Knight cannot bring ADA claim for herself |
| ADA claim for minor (A.G.) | A.G. was denied rights under ADA due to school actions | Allegations are too vague to state a claim | Court: Allegations insufficient; claim dismissed |
| Sufficiency of complaint | Filed factual allegations about ADA violations | Lacks detailed factual allegations | Court: Complaint lacks facts for plausible claim |
Key Cases Cited
- Braden v. Wal-Mart Stores, Inc., 588 F.3d 585 (8th Cir. 2009) (establishing Twombly/Iqbal pleading standard for facial plausibility)
- Crozier for A.C. v. Westside Community School District, 973 F.3d 882 (8th Cir. 2020) (non-attorney parents may not represent their minor children pro se)
- Sanders v. United States, 760 F.2d 869 (8th Cir. 1985) (liberal construction of pro se pleadings but subject to dismissal if no possible set of facts for jurisdiction)