Ragland v. NC State Board of Education, 5:16-cv-00288

Pro se plaintiff Ragland, a former public-school teacher, sued the NC State Board of Education and individual officials challenging his termination and actions against his teaching license, seeking damages and injunctive relief (expungement, reinstatement of license).
Plaintiff proceeded in forma pauperis; Magistrate Judge Swank issued an M&R recommending dismissal of federal monetary claims (immunity/failure to state a claim) but allowing injunctive claims against the Board to proceed; plaintiff objected and sought counsel.
The district court reviewed objections de novo where specific, and for clear error otherwise, and addressed appointment of counsel under the Fourth Circuit’s “exceptional circumstances” standard.
The court denied appointment of counsel, concluding the case is not complex and Ragland had not shown exceptional circumstances.
The court adopted the M&R as to dismissal of monetary claims based on Eleventh Amendment and quasi‑judicial immunity and declined supplemental jurisdiction over state-law claims.
The court rejected the M&R’s recommendation to permit injunctive relief against the Board, holding Younger abstention applies and alternatively that the complaint fails to state constitutional claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Appointment of counsel	Ragland requested counsel to assist presentation of claims	No constitutional right to counsel; appointment reserved for exceptional cases	Denied — no exceptional circumstances; case not complex
Monetary federal claims (damages)	Ragland seeks damages under § 1983 for termination and license actions	Eleventh Amendment and quasi‑judicial immunity bar monetary relief; failure to state claim	Dismissed — lack of subject‑matter jurisdiction (immunity) or failure to state a claim
Injunctive relief (expungement/reinstatement) — Younger abstention	Ragland seeks federal injunctive relief to expunge records and reinstate license; alleges state proceedings completed or ongoing	Board argues state disciplinary/license proceedings implicate important state interests, provide adequate forum; Younger bars federal intrusion	Dismissed — Younger abstention applies (ongoing proceedings and adequate state remedies); Rooker–Feldman alternative if state proceedings final
Merits of constitutional claims (due process, equal protection, Fourth Amendment)	Ragland alleges procedural due process violations, racial discrimination, and Fourth Amendment claims	Defendants contend pleadings are conclusory and lack factual support; Fourth Amendment inapplicable to administrative licensing	Dismissed — pleadings fail Iqbal/Twombly plausibility standards; Fourth Amendment claim fails as inapposite

Neitzke v. Williams, 490 U.S. 319 (frivolous complaint standard)
Ashcroft v. Iqbal, 556 U.S. 662 (pleading must be plausible; courts disregard conclusory allegations)
Younger v. Harris, 401 U.S. 37 (abstention from federal interference in certain ongoing state proceedings)
Middlesex County Ethics Comm. v. Garden State Bar Ass’n, 457 U.S. 423 (Younger applied to state disciplinary proceedings)
Huffman v. Pursue, Ltd., 420 U.S. 592 (exhaustion and ongoing‑proceedings concept under Younger)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (pleading standards — more than labels and conclusions)
Carnegie‑Mellon Univ. v. Cohill, 484 U.S. 343 (declining supplemental jurisdiction over state claims)
Gray v. Laws, 51 F.3d 426 (Eleventh Amendment immunity principles)
Ostrzenski v. Seigel, 177 F.3d 245 (quasi‑judicial immunity)