947 F. Supp. 2d 868
M.D. Tenn.2013Background
- SCMS operated as a public charter school in Nashville since 2009 under MNPS oversight and a Charter School Act regime.
- Board voted 8-1 on Nov. 13, 2012 to revoke SCMS’s charter based on underperformance, despite improving scores and safety steps.
- Center of dispute is reliance on recommendations by MNPS Director of Schools Register and Office of Innovation Director Coverstone to revoke the charter.
- Plaintiffs include Project Reflect, Inc. (sponsor), SCMS, and two SCMS parent representatives seeking to enjoin closure and vindicate due process/EP rights.
- Plaintiffs allege procedural due process and equal protection violations under 42 U.S.C. § 1983, challenging the state-law framework and Board’s ultravires actions.
- Court grants Defendants’ motions to dismiss; other motions denied as moot; case dismissed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Project Reflect has standing to sue as sponsor. | Project Reflect is the charter sponsor with contractual rights. | Charter schools are political subdivisions; standing to sue the state is limited. | Assume standing for analysis; court discusses standing but ultimately dismisses on merits. |
| Whether state remedies adequacy is required for procedural due process claim. | State remedies are inadequate to compensate for deprivation. | Adequacy of remedies not pled; mischaracterized as random/unauthorized act. | Court requires inadequate state remedies; ultimately dismisses due process claim for lack of entitlement. |
| Whether plaintiffs have a protected property interest in operating a charter school. | Sponsor/SCMS have a property interest via contract/statute. | Charter revocation discretionary; no entitlement under statute/charter. | No protected property interest; discretionary nature defeats entitlement. |
| Whether parents have a property interest in enrolling children in SCMS and whether equal protection applies. | Parents have statutory/constitutional right to attend charter school of choice. | No cognizable property right to attend a specific school; traditional schools not comparable. | No property interest for parents; no plausible class-of-one equal protection claim. |
Key Cases Cited
- Blazy v. Jefferson Cnty. Regional Planning Comm'n, 438 Fed.Appx. 408 (6th Cir. 2011) (due process requires notice and hearing prior to deprivation)
- Twombly v. Bell Atlantic Corp., 550 U.S. 544 (U.S. 2007) (pleading must state plausible claim, not mere speculation)
- Iqbal v. Ashcroft, 556 U.S. 662 (U.S. 2009) (pleading must include plausible factual content)
- Zinermon v. Burch, 494 U.S. 113 (U.S. 1990) (random and unauthorized acts warrant consideration of post-deprivation remedies)
- Hudson v. Palmer, 468 U.S. 517 (U.S. 1984) (predeprivation process may suffice when state can provide it)
- Matthew v. Eldridge, 424 U.S. 319 (U.S. 1976) (three-factor test for what process is due)
- Castle Rock v. Gonzales, 545 U.S. 748 (U.S. 2005) (property interest not implicated absent entitlement)