The Bullis-Purissima Elementary School v. Santa Clara County Board of Education
5:24-cv-08527
| N.D. Cal. | Jul 11, 2025Background
- Bullis-Purissima Elementary School (BCS), operating Bullis Charter School, is a high-performing public TK-8 charter school in Santa Clara County, California, seeking unconditional renewal of its charter.
- BCS alleges that the Santa Clara County Board of Education (SCCBOE) and Santa Clara County Office of Education (SCCOE) subjected it to adverse treatment, including heightened scrutiny and conditional renewal, due to BCS’s disproportionately high Asian student enrollment and low Hispanic enrollment relative to district demographics.
- Defendants gave BCS only a conditional charter renewal, requiring an MOU, citing concerns about underrepresentation of “historically underserved” student groups; BCS claims this is discriminatory and not applied to other charter schools.
- BCS sued for violations of Title VI of the Civil Rights Act, seeking injunctive and declaratory relief, as well as attorneys' fees.
- The SCCBOE’s conditions did not explicitly require racial quotas in admissions; BCS voluntarily signed the MOU but did so under protest.
- Defendants moved to dismiss for lack of subject matter jurisdiction (ripeness) and failure to state a claim; the court granted the motion to dismiss under Rule 12(b)(6) with leave to amend.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether BCS stated a Title VI disparate treatment claim | BCS is singled out and treated less favorably due to Asian makeup | No plausibly alleged disparate treatment; similarly situated not shown | Dismissed with leave to amend |
| Whether BCS required to use racial quotas unlawfully | SCCBOE's actions effectively force BCS to apply racial quotas | No express requirement for racial quotas or race consideration | Dismissed with leave to amend |
| Whether alleged harms are ripe for adjudication | Ongoing compliance burdens and reputational harm are present | No real or concrete injury as charter was renewed through 2030 | Not dismissed on ripeness grounds |
| Whether BCS can allege future harm based on conditions | Conditions imposed cause ongoing/future injury to school operations | No non-renewal risk until 2030, so injury is hypothetical | Amending complaint allowed |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for pleadings)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading standard; speculative claims insufficient)
- Grutter v. Bollinger, 539 U.S. 306 (Title VI standards mirror equal protection)
- White v. Lee, 227 F.3d 1214 (Rule 12(b)(1) factual attacks allow review of public record outside pleadings)
- Navarro v. Block, 250 F.3d 729 (Rule 12(b)(6) tests sufficiency of complaint)
- Lopez v. Smith, 203 F.3d 1122 (leave to amend standard)
- Foman v. Davis, 371 U.S. 178 (standards for granting leave to amend)
- Regents of Univ. of Cal. v. Bakke, 438 U.S. 265 (Title VI and equal protection relationship)