W. v. Santa Rosa City Schools

Background

A.W., through his guardian ad litem, filed a First Amended Complaint against Rincon Valley Middle School, Principal Amy Schlueter, and unnamed defendants. Santa Rosa City Schools, which had been incorrectly named as Rincon Valley, moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint states a legally sufficient claim.

The amended complaint alleged that A.W. experienced racial harassment, including repeated use of a racial slur, and that school personnel failed to protect him or discipline other students. It also alleged that A.W. received unequal punishment, was searched for drugs without evidence, was removed from classes, was barred from basketball tryouts, and was placed on a behavior-related restriction. The amended complaint asserted claims under Title VI of the Civil Rights Act of 1964, California Education Code section 220, and state negligence law.

California discretionary-act immunity

The District argued that California Government Code section 820.2 protected it from liability for the conduct underlying the negligence claim. That protection can apply to a public entity when the relevant employee’s conduct involved an authorized policy decision requiring a conscious balancing of risks and benefits. A ministerial act—an act that merely carries out an already established policy—does not receive the same protection.

The court declined to adopt a blanket rule that all school disciplinary decisions are protected. At the motion-to-dismiss stage, the District had not shown that the staff members who acted against A.W. had authority to exercise protected discretion or that their decisions were policy decisions rather than ministerial actions. The court therefore denied the motion to dismiss on section 820.2 immunity grounds without prejudice, meaning the District may raise the argument again if appropriate.

California Education Code section 220 claim

The court treated the District’s challenge to the request for an injunction as a challenge to A.W.’s section 220 claim. The amended complaint sought only injunctive relief on that claim and did not allege that A.W. had exhausted the administrative process required before seeking damages. Injunctive relief is exempt from that exhaustion requirement, but a plaintiff seeking prospective relief must still allege a real and immediate threat of future harm.

The court held that the amended complaint did not allege such a threat. The alleged conduct ended in April 2024, and the complaint did not say that A.W. continued to attend a school in the District or that similar conduct continued after his eighth-grade year. The court granted the motion to dismiss the section 220 claim, with leave to amend if A.W. could allege facts establishing a viable claim.

Rincon Valley as a defendant

The District argued that Rincon Valley was a sub-entity that could not be sued independently. A.W. did not dispute that Rincon Valley was an improper party and sought permission to name Santa Rosa City Schools instead. The discussion portion of the opinion states that Rincon Valley was dismissed with prejudice, while also stating that A.W. could amend to name the District. The order’s conclusion instead states that the motion to dismiss Rincon Valley was granted with leave to amend.

Disposition

The court stated that the District’s motion to dismiss was granted in part and denied in part: the section 820.2 immunity challenge was denied without prejudice; the motion to dismiss the section 220 claim was granted with leave to amend; and the motion concerning Rincon Valley was granted, with the opinion containing the conflicting descriptions noted above. Any amended complaint was due July 15, 2025 and could address only the deficiencies identified in the order.