W. v. Santa Rosa City Schools

Background

A.W., through his guardian ad litem, Sheria Weston, sued Santa Rosa City Schools, Principal Amy Schlueter, and Does 1–20. The complaint alleged racial harassment by another student, inadequate responses by school personnel, unequal discipline, searches and restrictions, and other discriminatory treatment. It asserted five claims: (1) race discrimination under California’s Unruh Civil Rights Act against Schlueter; (2) race discrimination under 42 U.S.C. § 1983 based on the Fourteenth Amendment against all defendants; (3) race discrimination under Title VI of the Civil Rights Act of 1964 against all defendants; (4) a violation of California Education Code section 220 against all defendants; and (5) negligence against all defendants.

The District moved to dismiss the Unruh Act, Section 1983, and Education Code section 220 claims. The court considered the factual allegations true for purposes of the motion to dismiss.

Unruh Act claim

The Unruh Act prohibits discrimination based on protected characteristics, including race, in covered business establishments. Relying on a California Supreme Court decision, the court held that a California public school district is not a covered “business establishment” when providing educational services. The court therefore concluded that the District could not be liable under the Unruh Act and that amendment would be futile. The opinion’s claim list identifies the Unruh claim as being against Principal Schlueter, while this part of the ruling specifically discusses the District’s liability.

Section 1983 claim

Section 1983 provides a method for seeking relief when someone acting under state authority violates a federal constitutional or statutory right. The District argued that it was an arm of the state and therefore immune from suit under the Eleventh Amendment. The court agreed, relying on Ninth Circuit authority that California school districts are state agencies entitled to that immunity. It found that none of the recognized exceptions to the immunity applied and rejected A.W.’s argument that state funding made the District a suable person under Section 1983. The court dismissed the Section 1983 claim with prejudice.

California Education Code section 220 claim

The District argued that A.W. had not completed the administrative process required before seeking civil remedies under Education Code section 220. The court held that A.W. had not alleged that he filed a complaint with the local educational agency and then appealed to the California Department of Education. It rejected his argument that another statutory provision excused those requirements. The court dismissed the section 220 claim with leave to amend if A.W. could allege that he completed the required administrative steps.

Disposition

The court granted the District’s motion to dismiss. The order states that A.W. may file an amended complaint consistent with the order by May 6, 2025. The opinion does not separately state a disposition for the Title VI or negligence claims, which were not among the claims the District moved to dismiss.