Brown v. Bagley

Background

Maurice A. Brown filed the case on behalf of his son, K.A.B., and himself. The opinion says Brown was representing himself and was not an attorney. The defendants are identified in the caption as Diane Bagley, Timothy D. Gilbert, Maple Grove School District 279 of Osseo, Kim Heil, and Rice Lake Elementary, School District 279. In the body, the opinion refers to Bagley as Dion Bagley, creating a name discrepancy in the opinion text.

Brown alleges that Rice Lake staff changed K.A.B.’s school transportation in March 2025 after a report that K.A.B. had assaulted another student on a bus. Brown says Bagley pressured him to sign a form moving K.A.B. from his regular bus to a special-needs van while Brown did not have his glasses and did not know what he was signing. Brown alleges that K.A.B. denied the assault, that later-reviewed video showed nothing, and that the transportation change remained in place. He also alleges that valid individualized education plan meetings later confirmed that no assault occurred, and that defendants failed to address his concerns about K.A.B. being attacked on the special-needs van.

Issues identified by the court

The court identified two threshold problems. First, it said a nonlawyer may not represent another person in federal court, so Brown could not assert claims on K.A.B.’s behalf. The court explained that a nonlawyer parent may bring certain claims under the Individuals with Disabilities Education Act on the parent’s own behalf to protect the parent’s own rights.

Second, the court explained that a parent generally must complete the Individuals with Disabilities Education Act’s administrative process before bringing those claims in federal court. The court said nothing in Brown’s current filings showed that he had completed that process. It therefore encouraged Brown to file an amended complaint explaining in greater detail how he had exhausted the administrative remedies.

Rulings and directives

The court directed Brown to file an amended complaint by July 28, 2025. If he did not do so, the court said it would review the case and his application to proceed without prepaying fees or costs based on the current complaint. The order did not decide the underlying allegations about K.A.B.’s transportation or any possible Individuals with Disabilities Education Act claim.

The court denied Brown’s motion to appoint counsel without prejudice. It explained that there is no constitutional or statutory right to appointed counsel in civil cases and that appointment is left to the trial court’s discretion. Although some relevant factors might favor Brown, the court said it was unclear whether the case could proceed in its current form.

The court also ordered a separate referral of Brown to the Federal Bar Association’s Pro Se Project for possible consultation with a volunteer attorney. The court explained that the project may help Brown draft an amended complaint but that the referral does not guarantee representation.