WHITE v. RUTGERS UNIVERSITY, THE STATE UNIVERSITY OF NEW JERSEY
3:23-cv-02597
| D.N.J. | Nov 27, 2024Background
- Plaintiff Robert White, a disabled undergraduate at Rutgers, had an accommodation plan through the university's Office of Disability Services, designed to allow equal access to his education.
- Over multiple semesters, White alleged that various professors failed to implement these accommodations, affecting his academic performance and resulting in lower grades or withdrawal from classes.
- White engaged legal counsel to assist with enforcing accommodation plans and navigating Rutgers’s internal appeals process, but claimed Rutgers was unresponsive or delayed in addressing his complaints.
- White filed ten claims against Rutgers, including federal claims under the ADA, Rehabilitation Act, § 1983, and various state law claims.
- Rutgers moved to dismiss all counts. The court considered whether White sufficiently alleged intentional discrimination, retaliation, or equal protection violations, as well as the court’s jurisdiction over his state law claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Disability discrimination under ADA/504 | Rutgers, through professors, failed to implement accommodations, harming him | No deliberate indifference by Rutgers; only alleged inaction | Dismissed; no sufficient allegation of Rutgers’s deliberate indifference |
| Retaliation under ADA/504 | Rutgers retaliated via lack of communication and delayed grievance process | No adverse or retaliatory action plausibly alleged | Dismissed; alleged actions not adverse or retaliatory under these statutes |
| Equal protection claim (§ 1983) | Treated differently than non-disabled peers | White failed to identify any similarly situated students | Dismissed; no allegation of similarly situated individuals receiving different treatment |
| Supplemental state claims | State claims should proceed with federal claims | No original jurisdiction remains after federal dismissals | Dismissed without prejudice; court declined supplemental jurisdiction |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard for federal complaints)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (courts may ignore conclusory statements when evaluating complaints)
- Blunt v. Lower Merion Sch. Dist., 767 F.3d 247 (3d Cir. 2014) (elements of an equal protection claim under § 1983)
- D.E. v. Cent. Dauphin Sch. Dist., 765 F.3d 260 (3d Cir. 2014) (elements and standard of deliberate indifference for ADA/504 claims)