Thompson v. Hayward Unified School District
- James Donato
- 3:20-cv-01964
- U.S. District Court · Northern District of California
- 3
In Thompson v. Hayward Unified School District, Judge Donato dismissed the federal claims with prejudice and remanded the state claims to state court.
Najee Thompson and the plaintiffs’ state-law claims were affected: the § 1983 damages claims against Hayward Unified School District were dismissed with prejudice, while the negligence and mental-anguish claims were remanded to California state court.
What happened
In Thompson v. Hayward Unified School District, pro se plaintiff Najee Thompson alleged that the school district violated his daughter’s religious-freedom and equal-protection rights by not offering pork-free school meals. He sought damages under federal civil-rights law, along with damages for negligence and mental anguish under California law.
The court held that the school district was protected by Eleventh Amendment immunity from Thompson’s federal damages claims. It dismissed those claims with prejudice because the problem could not be fixed by amending the complaint. After the federal claims were dismissed, the court declined to keep the remaining state-law claims and ordered the case remanded to the Superior Court of California for Alameda County.
Judge James Donato discharged the order requiring Thompson to explain why the case should not be dismissed for failure to prosecute, then resolved the school district’s motion to dismiss on the merits.
The detailed version
- Thompson v. Hayward Unified School District · No. 3:20-cv-01964
- James Donato
- Mar. 15, 2021
Background
Pro se plaintiff Najee Thompson sued Hayward Unified School District under 42 U.S.C. § 1983. He alleged that the district violated his daughter’s First Amendment freedom-of-religion right and Fourteenth Amendment equal-protection right by failing to provide school meals that were free of pork. He requested $100,000 for the alleged religious-freedom violation and another $100,000 for the alleged equal-protection violation. The complaint also asserted California-law claims for negligence and mental anguish.
The district moved to dismiss the first amended complaint. After Thompson did not timely oppose the motion, the court ordered him to show why the case should not be dismissed for failure to prosecute. Thompson filed two declarations, and the court discharged that order before deciding the motion to dismiss.
Federal Claims
The court applied Ninth Circuit precedent holding that California school districts are immune from suit under the Eleventh Amendment. The court concluded that this immunity barred Thompson’s claims for damages under § 1983. Because the defect could not be fixed by amendment, the court dismissed the § 1983 claims against the district with prejudice.
State-Law Claims and Disposition
The district also asked the court to dismiss the negligence and mental-anguish claims based on immunity under the California Government Claims Act. The court did not decide that request. Instead, after dismissing the only federal claims, it declined to exercise supplemental jurisdiction over the remaining state-law claims. Because the case was at an early stage, the court ordered it remanded to the Superior Court of California for the County of Alameda.
Judge James Donato issued the order on March 15, 2021.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.