G.C. v. South Washington County School District 833
- David Doty
- 0:17-cv-03680
- U.S. District Court · District of Minnesota
- 4
In G.C. v. South Washington County School District 833, Judge Doty dismissed the moot case without prejudice and denied pending motions as moot.
G.C. and the defendants, South Washington County School District 833 and Dr. Keith Jacobus. The case ended without a decision on the requested accommodations.
What happened
G.C. v. South Washington County School District 833 concerned requested school accommodations for G.C., who allegedly experienced Electromagnetic Hypersensitivity Syndrome. Before the court ruled on pending motions, G.C. stopped attending a school in the District.
The court ruled that the case was no longer live because the requested accommodations concerned G.C.’s former school and would not affect his current education. The court also said any future accommodations might differ, so it could not provide effective relief without deciding a hypothetical dispute.
Judge David S. Doty dismissed the case without prejudice and denied the pending motions as moot without prejudice. The court did not decide whether G.C. was entitled to the requested accommodations.
The detailed version
- G.C. v. South Washington County School District 833 · No. 0:17-cv-03680
- David Doty
- Sept. 23, 2019
Background
G.C. sought an order requiring South Washington County School District 833 and its superintendent, Dr. Keith Jacobus, to provide accommodations because G.C. allegedly suffers from Electromagnetic Hypersensitivity Syndrome. At oral argument, G.C.’s counsel identified five requested accommodations: sitting as far as possible from a classroom Wi-Fi access point, connecting G.C.’s computer by Ethernet cable, using an Ethernet connection in the library for assignments requiring Internet access, reducing classroom Wi-Fi, and allowing G.C. to go to the nurse’s office when he felt unwell.
Before the court ruled on the District’s motions for summary judgment and to exclude expert testimony, G.C. stopped attending school in the District. G.C. argued that the dispute was not moot because he might return to his former school. The District also argued that the dispute could resurface in the future and noted that it had already spent substantial resources defending the case.
Court’s Analysis
The court held that the case was moot because it could no longer provide effective relief. The requested accommodations would not affect G.C.’s current educational setting because he attended a different school in another district. The court treated accommodations G.C. might seek from the new school as a separate matter.
The court also found that it had little confidence that the listed accommodations would be satisfactory if G.C. returned to his former school. It reasoned that the requested relief might not fit future circumstances or cover all needed accommodations, and that G.C.’s symptoms might differ in type or severity later. Because the dispute was moot, the court did not reach the merits.
Ruling and Effect
Judge David S. Doty ordered that the case be dismissed without prejudice. The court also ordered that the pending motions be denied as moot without prejudice. The opinion does not decide whether G.C. was entitled to any accommodation or whether the alleged condition qualified for legal protection.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.