Sepúlveda-Villarini v. Department of Education
628 F.3d 25
| 1st Cir. | 2010Background
- consolidated appeals from the District of Puerto Rico; plaintiffs Sepúlveda and Velázquez allege failure to accommodate under ADA Title I and §504 of the Rehabilitation Act; defendants include Puerto Rico Department of Education and its officials; district court dismissed on Rule 12(b)(6) grounds; on appeal the First Circuit vacates and remands; issues center on pleading a claim for failure to accommodate and the alleged causal link between class size and disability-related harm; district court dismissed related Title II and Puerto Rico law claims as moot or unsupported; the appellate court conducts a plausibility review under Twombly/Iqbal and clarifies pleading standards for these claims
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Do Sepúlveda and Velázquez plead a plausible Title I/§504 failure-to-accommodate claim? | Plaintiffs allege disability, accommodations made for years, then an increased class size after 2007-08; this constitutes a failure to accommodate. | District court required more detailed factual support linking class size to inability to teach; pleadings insufficient. | Yes; claims plausibly stated. |
| Is there a plausible causal link between increased class size and health deterioration? | Allegations show deterioration after size increase, implying causal connection between accommodations change and harm. | No explicit medical causation pleaded; insufficient to plead causation at the pleading stage. | Yes; plausibility shown, not requiring proven causation at this stage. |
| Are Title II, sovereign immunity, and Puerto Rico-law claims properly resolved on the pleadings? | Claims under Title II and related state-law theories should proceed; immunity not absolute at pleading stage. | Title II not applicable to employment discrimination; sovereign immunity bars certain relief; state-law claims lack federal question basis. | The district court's rulings on these issues are vacated and remanded. |
Key Cases Cited
- Enica v. Principi, 544 F.3d 328 (1st Cir. 2008) (pleading elements for ADA/§504 failure to accommodate)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (S. Ct. 2007) (plausibility standard for pleading)
- Ashcroft v. Iqbal, 129 S. Ct. 1937 (S. Ct. 2009) (plausibility standard applied to complaints)
- Twombly v. Bell Atl. Corp., 550 U.S. 544 (S. Ct. 2007) (pleading must state plausible claim, not mere possibility)
- Ex parte Young, 209 U.S. 123 (U.S. 1908) (sovereign immunity against damages not available in certain suits for prospective relief)