L.T. v. Eleanor Murray Fallon Middle School

Background

L.T., through his guardian ad litem and father, Lance Turner II, sued Dublin Unified School District and other defendants. The complaint alleges that L.T., an African American student who attended Eleanor Murray Fallon Middle School, was subjected to repeated racial slurs, harassment, bullying, and other incidents during the 2022–2023 school year. It also alleges that school personnel responded inadequately. The complaint asserted six causes of action: race discrimination under 42 U.S.C. § 1983; race discrimination under Title VI of the Civil Rights Act of 1964; violation of California’s Unruh Civil Rights Act; negligence; intentional infliction of emotional distress; and violation of California Education Code section 220.

The District moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint alleges enough facts to support a legally plausible claim. At this stage, the court generally accepts well-pleaded factual allegations as true and views them favorably to the plaintiffs.

Rulings

Section 1983 claim

The court held that a California school district is treated as an arm of the state for purposes of the relevant immunity rules and therefore is not a “person” that can be sued for damages under § 1983. The plaintiffs argued that the District could be liable because it receives state funding and because individual employees were described in the complaint. The court rejected that argument because those employees were not named as defendants. It granted the motion to dismiss the § 1983 claim with leave to amend to the extent the plaintiffs sought to bring the claim against individual defendants for injunctive relief.

Title VI claim

Title VI prohibits race discrimination in federally funded programs. The court found that the plaintiffs sufficiently alleged a racially hostile educational environment, District notice of the alleged harassment, and failure to adequately address it. The court concluded that whether the District acted with “deliberate indifference”—meaning an unreasonable failure to respond to known discrimination—was a factual question better addressed later in the case. It denied the motion to dismiss the Title VI claim.

Unruh Act claim

The court held that public schools and school districts are not “business establishments” covered by California’s Unruh Civil Rights Act when providing educational services. It granted the motion to dismiss the Unruh Act claim without leave to amend.

Negligence and intentional infliction of emotional distress

The court explained that California public-entity tort liability must be based on an authorizing statute. Because the complaint did not identify a statute authorizing the District’s liability and instead relied on common-law theories, the court granted the motion to dismiss the negligence and intentional-infliction-of-emotional-distress claims with leave to amend.

California Education Code section 220 claim

Section 220 prohibits specified discrimination, including race discrimination, in qualifying educational programs. The court found that the plaintiffs sufficiently alleged severe and offensive harassment, District knowledge, and deliberate indifference. It also found that the District’s argument concerning immunity for discretionary disciplinary decisions was premature because the pleadings did not establish that the relevant individuals had consciously and deliberately weighed policy objectives. The court denied the motion to dismiss the section 220 claim.

Request for judicial notice and conclusion

The court denied the District’s request for judicial notice of certain District policies because the policies were not relevant to the motion. Overall, the court granted in part and denied in part the District’s motion to dismiss. Plaintiffs may file an amended complaint by September 4, 2024.