Lansberry v. Altoona Area Sch. Dist., 356 F. Supp. 3d 486

Seventh-grader W.J.L. was repeatedly bullied at Altoona Junior High during 2016–17, including physical assaults, name-calling, and online harassment; some incidents occurred in view of school staff and W.J.L. sought counseling.
After a severe day of bullying, W.J.L. committed suicide on May 18, 2017; police investigations linked bullying as a contributing factor and identified eyewitnesses and electronic messages indicating suicidal ideation.
Multiple other students at the school reported persistent bullying and complaints that school officials failed to follow policy, notify parents, or discipline perpetrators; school officials conceded policy deficiencies and hired external counsel whose recommendations were not reviewed.
Plaintiff Marc Lansberry (individually and as administrator of W.J.L.’s estate) sued AASD and officials asserting a Monell § 1983 claim (failure to train/deliberate indifference to constitutional right to bodily integrity), and state wrongful-death and survival claims.
The district court previously dismissed related § 1983 state-created-danger claims with prejudice and allowed amendment on other claims; after a Second Amended Complaint, defendants moved to dismiss.
The court dismissed the Monell claim and attendant state-law wrongful-death and survival claims with prejudice, concluding Lansberry failed to plausibly allege an underlying constitutional violation by the school district.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether AASD can be liable under Monell for deliberate indifference/failure to train causing deprivation of student’s right to bodily integrity	Lansberry contends AASD had notice of pervasive bullying, failed to train staff and enforce policies, and that deliberate indifference caused a constitutional violation (bodily integrity) leading to W.J.L.’s suicide	AASD argues plaintiff failed to plead any cognizable constitutional violation because the Fourteenth Amendment does not generally impose a duty to protect students from private actors (other students)	Court: Dismissed Monell claim — plaintiff failed to plausibly allege an underlying constitutional violation (no state duty to protect from private third-party bullying)
Whether state wrongful-death and survival claims survive absent a viable federal § 1983 claim	Lansberry relies on § 1983 Monell claim as the federal predicate for survival and wrongful-death recovery	Defendants argue those state claims fail if Monell is deficient because wrongful-death and survival actions require an underlying cognizable claim	Court: Dismissed wrongful-death and survival claims with prejudice as they rest on the dismissed Monell claim

Monell v. Department of Social Services, 436 U.S. 658 (U.S. 1978) (municipality liable under § 1983 only for its own policy/custom or deliberate indifference)
DeShaney v. Winnebago County Department of Social Services, 489 U.S. 189 (U.S. 1989) (Due Process Clause does not generally impose a duty on the State to protect individuals from private actors)
Morrow v. Balaski, 719 F.3d 160 (3d Cir. 2013) (en banc) (public schools generally have no constitutional duty to protect students from private actors)
Bridges ex rel. D.B. v. Scranton School District, [citation="644 F. App'x 172"] (3d Cir.) (Monell claim fails where no underlying constitutional violation for student-on-student bullying)
Gayemen v. School District of City of Allentown, [citation="712 F. App'x 218"] (3d Cir.) (affirming dismissal of Monell claim where no underlying constitutional violation)
City of Canton v. Harris, 489 U.S. 378 (U.S. 1989) (deliberate indifference theory for failure-to-train Monell claims)
Board of County Commissioners v. Brown, 520 U.S. 397 (U.S. 1997) (Monell causation standard and deliberate indifference)
Connick v. Thompson, 563 U.S. 51 (U.S. 2011) (deliberate indifference requires notice that omission causes constitutional violations)
Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (pleading standard for plausible claims)
Bell Atlantic v. Twombly, 550 U.S. 544 (U.S. 2007) (pleading rule requiring plausible claim)