Steele v. Success Academy Charter Schools, Inc.

Background

Valerie Steele, the mother and legal guardian of J.S., alleged that J.S. was discriminated against because of a disability while attending Success Academy Hell’s Kitchen. The opinion states that J.S. had been diagnosed with attention-deficit/hyperactivity disorder. Steele alleged that the school and its principal, Michael LaFrancis, failed to accommodate J.S., imposed disciplinary consequences and suspensions related to his disability, overreacted to some incidents, and failed to provide outside medical attention after another incident. Steele ultimately removed J.S. from the school.

The operative complaint named Success Academy Charter Schools, Inc.; Success Academy Hell’s Kitchen; Michael LaFrancis; Success Academy’s chief executive officer, Eva Moskowitz; and ten members of Success Academy’s Board of Trustees. Steele asserted a Section 504 claim against Success Academy, the school, and LaFrancis, and a claim under 42 U.S.C. § 1983 against Success Academy, the Trustees, and Moskowitz based on alleged policies, customs, and failures to train, supervise, or discipline. The motion addressed the individual defendants: LaFrancis, Moskowitz, and the Trustees.

Legal Standard

The court applied the standard for a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6). At that stage, a complaint must contain enough factual allegations to make the asserted claim plausible, and the court accepts the complaint’s allegations as true and draws reasonable inferences for the party opposing dismissal.

Court’s Reasoning

Section 504 of the Rehabilitation Act prohibits disability discrimination against an otherwise qualified person in a program or activity receiving federal financial assistance. The court relied on Second Circuit precedent holding that Section 504 does not allow suits against individuals in their individual capacities.

Steele also relied on § 1983. Section 1983 can sometimes be used to enforce rights created by federal statutes, but the court explained that it cannot be used when Congress intended a different, comprehensive enforcement system. The court concluded that the Rehabilitation Act’s detailed remedial scheme—including the remedies and procedures incorporated from Title VI—showed that Congress did not intend § 1983 to provide an additional route for imposing individual liability for Section 504 violations.

The court acknowledged that the Second Circuit had not resolved this precise issue and that some district courts had allowed such claims. It found more persuasive the contrary decisions from several courts of appeals and a majority of district courts in the circuit. The court also concluded that cited decisions, including Weixel, did not resolve whether defendants could be sued in their individual capacities.

Disposition

The court concluded that Steele could not use § 1983 to obtain the individual liability that the Rehabilitation Act does not provide. It granted Defendants’ partial motion to dismiss and dismissed Steele’s claims against Michael LaFrancis, Eva Moskowitz, and the ten Trustees. The opinion states that this resolved Docket Number 57.