Knight v. Minneapolis Public Schools

Background

Desiree Knight, acting as legal guardian of her minor daughter, A.G., sued Minneapolis Public Schools under the Americans with Disabilities Act (ADA). The opinion states that A.G. attends Follwell Community School, receives special education services under the Individuals with Disabilities Education Act, and is entitled to accommodations under the ADA.

Knight alleged three ADA violations: school staff restrained A.G. on January 13, 2025, without informing Knight or providing requested information; the school did not provide timely and adequate special education services, delaying A.G.’s individualized education plan; and the school did not timely provide specialized transportation called for in the plan. The complaint did not provide details about these allegations.

Knight sought compensatory damages, punitive damages, and attorney’s fees. Although she brought the case on behalf of A.G., she also sought damages for herself based on financial losses, future income loss, lost educational opportunities, and time spent addressing the alleged violations. The opinion identifies Knight as proceeding without a lawyer.

Court’s Analysis

The court applied the standard for a motion to dismiss for failure to state a claim. Under that standard, a complaint must include enough factual matter to make relief plausible, rather than relying only on labels, conclusions, or a formulaic statement of the legal elements. The court also said that it must read a self-represented complaint liberally.

The court concluded that Knight had not stated an ADA claim on her own behalf because she did not allege that she herself had been subjected to an ADA violation. As a result, she was not entitled to damages for her claimed personal losses.

The court also held that a nonlawyer parent may not represent a minor child without a lawyer, even when the child cannot bring the claim independently. Knight therefore could not litigate A.G.’s claim while representing herself. In addition, the court stated that the allegations concerning each of the three alleged ADA violations were vague and lacked a basis for concluding that Minneapolis Public Schools violated the ADA, even after considering Knight’s later submissions.

Disposition

The court granted Minneapolis Public Schools’ motion to dismiss. It dismissed the case without prejudice, allowing Knight to retain a lawyer if she chose to continue pursuing the matter on A.G.’s behalf. The order directed that judgment be entered accordingly.