Doe, John v. Saint. Paul Conservatory for the Performing Arts

Background

John Doe, represented by his parents, James Doe and Jane Doe, was a student at Saint Paul Conservatory for the Performing Arts, which the opinion describes as a public charter school. The school told him that three female students had complained that he touched them inappropriately. Doe denied the allegations, although the dean noted that he admitted touching multiple female students. The school suspended him for three days. After he returned, he was bullied and ostracized, and protesters confronted him outside the school. He stopped attending the school the next day.

Doe initially brought claims under 42 U.S.C. § 1983 for denial of due process and an invasion-of-privacy claim. The court later dismissed those claims with prejudice, while a negligence claim remained. Doe then filed an amended complaint asserting only negligence under state law. He also sought leave to add a claim under Title IX based on the school’s handling of the allegations, its investigation, and its response to his complaints of harassment.

Motion for Leave to Amend

The court denied Doe’s request to file a second amended complaint. It concluded that the proposed Title IX claim was futile, meaning it would not survive a motion to dismiss. The proposed complaint alleged that the school failed to follow its Title IX policies and acted because of Doe’s sex or gender, but the court found those allegations conclusory. The court also found that Doe did not plead facts casting doubt on the disciplinary outcome or showing that the process or outcome resulted from sex or gender bias.

The court separately stated that the amendment request effectively sought reconsideration of the magistrate judge’s earlier decision denying leave to add a Title IX claim. Because Doe had not sought the required permission to file a reconsideration motion, the court considered the request improper. The court further stated that, even if permission had been properly requested, Doe had not shown the compelling circumstances required for reconsideration.

Motion to Dismiss and Jurisdiction

The operative amended complaint asserted only a state-law negligence claim. Federal-question jurisdiction exists for claims arising under federal law, and diversity jurisdiction may exist when the parties are citizens of different states and more than $75,000 is at stake. The court concluded that the amended complaint did not assert a claim within its original jurisdiction. Doe acknowledged that the court no longer had original jurisdiction and asked the court either to exercise supplemental jurisdiction over the negligence claim or to dismiss it without prejudice.

Supplemental jurisdiction allows a federal court to hear related state-law claims when the court has original jurisdiction over other claims. The court ruled that it could not exercise supplemental jurisdiction because no claim within its original jurisdiction remained. It added that, even if supplemental jurisdiction were available, it would decline to exercise it because negligence was the only remaining claim.

Disposition

The court denied Plaintiff’s Motion for Leave to Amend Complaint. It granted Saint Paul Conservatory for the Performing Arts’ Motion to Dismiss Amended Complaint. It dismissed the amended complaint without prejudice, meaning the disposition did not bar refiling the claim on that basis. The opinion states that judgment was to be entered accordingly.